State v. Lane, 749 S.E.2d 165

Lane was convicted of first-degree burglary for firearms stolen from Mark McSwain’s gun safe on April 21, 2011.
Pamela Holladay testified a burgundy four-door car with a paper tag and primer panel pulled into McSwain’s driveway that evening, and two people were in the vehicle.
McSwain discovered the guns missing around 4:30 p.m. and later found an unemployment-office paper in the grass in his yard.
Deputy Torres testified the unemployment paper could have arrived after 6:00 p.m. and that Lane had visited the unemployment office that day, about two to three miles from McSwain’s home.
Detective Dow acknowledged there were no eye-witness identifications of who was in the car or who entered the residence, and no fingerprints tied to Lane were found.
Lane was sentenced to 215 months’ imprisonment after the trial court denied a directed-verdict motion; the defense appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Directed verdict based on lack of substantial evidence	Lane argues no substantial circumstantial evidence proves guilt.	Lane contends the State failed to prove identity and the offense beyond a reasonable doubt.	Directed verdict should have been granted.
Circumstantial-evidence jury instruction	Lane requested a circumstantial-evidence instruction.	Lane asserts proper instruction was not given to the jury.	Court declines to address; dispositive issue is the directed verdict.

State v. Brannon, 388 S.C. 498 (Ct.App. 2010) (directed-verdict standard when evidence fails to prove the offense)
State v. Sterling, 396 S.C. 599 (Ct.App. 2012) (view evidence in light favorable to State on directed-verdict review)
State v. Odems, 395 S.C. 582 (Ct.App. 2011) (substantial circumstantial evidence required to sustain conviction)
Gibbs v. State, 403 S.C. 484 (Ct.App. 2013) (identity of the defendant is an element proven beyond reasonable doubt)
State v. Spears, 403 S.C. 247 (Ct.App. 2013) (appellate review of trial court factual findings)