State v. Dickerson
395 S.C. 101
S.C.2011Background
- Dickerson convicted of murder, kidnapping, and criminal sexual conduct; sentenced to death after jury recommendation.
- Roper tortured for ~36 hours; death caused by cumulative injuries; evidence shows Dickerson as primary actor.
- Juror 370 questioned on death-penalty views; circuit court found juror qualified after voir dire.
- Cross-examination of pathologist Dr. Schandl limited; urine-screen evidence deemed unreliable and prejudicial.
- District court denied request to charge on accessory after the fact; Dickerson argued it is a lesser-related offense.
- Defense attempted to introduce Watson’s testimony on execution impact; court excluded as improper penalty- phase evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Juror qualification for potential death-penalty verdict | Dickerson contends Juror 370 was a burden shifter. | State argues juror could follow court instructions and wait for evidence. | Juror qualified; record supports court’s discretion finding no automatic death-penalty bias. |
| Cross-examination of pathologist regarding urine screen | Dickerson contends urinalysis results should be admitted to show cocaine use. | State argues urine test is unreliable and irrelevant to cause of death. | Exclusion not an abuse of discretion; does not challenge autopsy findings. |
| Charge on accessory after the fact | Dickerson seeks jury instruction on accessory after the fact as a lesser-related offense. | Beck framework does not require charge on lesser-related offenses. | No error; accessory after the fact not a lesser-related offense requiring charge under Hopkins. |
| Witness on execution impact during penalty phase | Watson would testify to familial impact to argue mercy. | Eddings/Wise restrict penalties evidence to defendant’s character and mercy, not punishment itself. | Court did not abuse discretion; execution-impact evidence improper as penalty recommendation. |
Key Cases Cited
- Morgan v. Illinois, 504 U.S. 719 (U.S. 1992) (juror must be able to consider aggravating/mitigating evidence; automatic death penalty disallowed)
- Beck v. Alabama, 447 U.S. 625 (U.S. 1980) (need for jury to have third option; reliability of verdict)
- Hopkins v. Reeves, 524 U.S. 88 (U.S. 1998) (no constitutional right to charge on lesser-related offenses; Beck framework limited)
- State v. Gentry, 363 S.C. 93 (S.C. 2005) (indictment notice and defendant challenge; limits on charging lesser-related offenses)
- State v. Fuller, 346 S.C. 477 (S.C. 2001) (accessory after the fact not a lesser-included offense; jury instruction not required)
- State v. Copeland, 278 S.C. 572 (S.C. 1982) (proportionality review limited to cases where death imposed; framework for review)
- State v. Wise, 359 S.C. 14 (S.C. 2004) (penalty-phase limits on certain testimony; mercy vs. opinion on punishment)
- State v. Northcutt, 372 S.C. 207 (S.C. 2007) (mitigation and credibility standards in penalty phase)