720 S.E.2d 31
S.C.2011Background
- Inman pleaded guilty to murder, first-degree burglary, first-degree criminal sexual conduct, and kidnapping in a capital case.
- Judge sentenced Inman to death for murder and two consecutive 30-year terms for burglary and criminal sexual conduct.
- Inman asserted his plea was invalidly conditional because defense argued he was entitled to a jury sentencing.
- The sentencing proceedings involved alleged prosecutorial misconduct based on the Solicitor's treatment of a defense expert, Dr. Loring.
- Defense sought mistrial and recusal of the Solicitor’s Office; the court denied, then later conducted court-witness testimony and considered mitigation evidence.
- Court ultimately affirmed the guilty plea and the death sentence after proportionality review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of guilty plea conditioned on jury sentencing | Inman argues plea was conditional due to preservation of sentencing issue | State contends plea was unconditional and valid | Plea was unconditional; valid despite discussions on appeal capsulation. |
| Recusal/Questioning Solicitor as defense witness | Inman seeks recusal and to question Solicitor about misconduct | Solicitor's testimony not necessary; questioning would be cumulative | Judge did not abuse discretion; no mandatory recusal or necessity to call Solicitor. |
| Witness intimidation by Solicitor regarding Dr. Loring | Conduct amounted to prosecutorial misconduct and intimidation | Immunity and witness testimony mitigated prejudice | Solicitor engaged in prosecutorial misconduct; no mistrial warranted given bench nature and testimony existing. |
| Mistrial due to prosecutorial misconduct | Mistrial warranted due to prejudice from misconduct | Prejudice not shown; evidence strong and bench trial less prejudicial | No mistrial; sentencing not undermined due process; conviction stands. |
Key Cases Cited
- Downs v. State, 386 S.C. 93 (2009) (unconditional capital plea where evidence preserves issue but does not affect guilt)
- Truesdale v. State, 278 S.C. 368 (1982) (unconditional guilty plea where no reservation of guilt challenge)
- Hill v. Lockhart, 474 U.S. 52 (1985) (standard to determine validity of guilty plea)
- State v. Williams, 326 S.C. 130 (1997) (prosecutorial intimidation requires substantial interference and prejudice)
- State v. Laney, 367 S.C. 639 (2006) (early example of Solicitor misconduct in capital case)