773 S.E.2d 906
S.C.2015Background
- Victim was assaulted on April 5, 2006; she described forcible sexual assault by a man nicknamed “Black.”
- Police quickly located Respondent (Daniel Jenkins), who was known locally as “Black,” naked and sleeping near the scene; victim identified him within ~30 minutes.
- Medical rape exam showed facial and genital injuries, defensive wounds, and semen on vaginal and rectal swabs; a candleholder at the scene bore two fingerprints matching Respondent.
- Police obtained a warrant for Respondent’s DNA based on an affidavit; DNA from the swabs matched Respondent’s profile.
- Respondent moved to suppress the DNA, arguing the affidavit lacked probable cause (omitted sources, investigative facts, and rape exam results); trial court denied suppression and jury convicted Jenkins of first-degree criminal sexual conduct; life sentence imposed due to prior convictions.
- Court of Appeals found the warrant invalid and remanded for an evidentiary hearing on inevitable discovery; the State sought certiorari and this Court considered whether the erroneous admission of DNA was harmless error.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Jenkins) | Held |
|---|---|---|---|
| Whether erroneous admission of DNA obtained under an invalid warrant was harmless error | DNA was compelling but not necessary; other independent evidence proves guilt; even if warrant defective, conviction should stand without new trial | Admission of DNA was prejudicial and central to identity; error not harmless and requires new trial (or evidentiary hearing re: inevitable discovery) | Harmless beyond a reasonable doubt; conviction reinstated |
| Whether remand for an evidentiary hearing on inevitable discovery was required | Not necessary because error was harmless; thus no need to decide inevitable discovery | Court of Appeals’ remand was appropriate because State should have opportunity to prove DNA would have been inevitably discovered | Majority: remand unnecessary; reversed court of appeals’ remand |
Key Cases Cited
- Nix v. Williams, 467 U.S. 431 (establishing and explaining the inevitable discovery doctrine)
- Arizona v. Fulminante, 499 U.S. 279 (distinguishing structural versus trial errors for harmless-error analysis)
- State v. Mouzon, 326 S.C. 199 (S.C. 1997) (discussing Fulminante and structural/trial error framework)
- State v. Byers, 392 S.C. 438 (2011) (harmless-error inquiry is fact-intensive; assess materiality and prejudice in context)
- State v. Jennings, 394 S.C. 473 (2011) (erroneous admission not harmless where credibility of witnesses and absence of physical evidence made error critical)
- State v. Black, 400 S.C. 10 (2012) (appellate review: legal errors reviewed de novo; factual findings binding unless clearly erroneous)