State v. Patterson
425 S.C. 500
| S.C. Ct. App. | 2019Background
- May 9, 2012 armed robbery at K&M Jewelry; victim Mancine fired at robber whose fedora fell at scene.
- Fedora sent to SLED; DNA profile extracted and entered into CODIS, producing a database match to James Patterson.
- Police showed a photo lineup; Mancine identified Patterson; police later collected Patterson's DNA and matched it to the fedora sample.
- Patterson arrested and indicted for armed robbery, grand larceny, and weapon during commission of a violent crime; jury convicted and trial court sentenced him to 20 years.
- At trial, State elicited expert DNA testimony (Boehm) and SLED database-unit testimony (Fields); Patterson objected to authentication/chain-of-custody and Rule 404(b) implications from database testimony.
- Patterson also objected to the trial court's opening remark that trial is a "search for the truth," arguing it shifted the burden of proof.
Issues
| Issue | Patterson's Argument | State's Argument | Held |
|---|---|---|---|
| Authentication / chain of custody for DNA database match | State failed to authenticate the DNA entry in CODIS and did not prove chain of custody for the profile that produced the initial match | Authentication satisfied by expert testimony, distinctive profile IDs, and independent testing of Patterson's post-arrest sample | Court: Admission proper—authentication met; independent match to arrested sample cured database chain gaps |
| DNA database testimony as improper 404(b) evidence of prior bad acts | Testimony implied Patterson had prior convictions (only reason DNA would be in database) and was therefore prejudicial | Database testimony was descriptive of investigative method, not evidence of prior convictions; many reasons DNA may be in database | Court: No abuse—reference to database was relevant, probative, and not unduly prejudicial |
| Trial court’s "search for the truth" opening remark | Remark impermissibly shifted burden of proof to jury, prejudicial | Even if improper, the remark was isolated; trial court later correctly instructed on reasonable doubt and gave supplemental instructions | Court: Statement was error but harmless; conviction stands |
| Harmlessness given strength of evidence | N/A (implicit) | Evidence (eyewitness ID, surveillance, van repair, DNA match with extremely low random-match probability) overwhelming | Court: Any errors were not prejudicial in light of overwhelming evidence; affirm conviction |
Key Cases Cited
- State v. Pagan, 369 S.C. 201, 631 S.E.2d 262 (2006) (admission of evidence reviewed for abuse of discretion)
- State v. Hatcher, 392 S.C. 86, 708 S.E.2d 750 (2011) (chain-of-custody goal is to ensure item is what proponent claims)
- State v. Taylor, 360 S.C. 18, 598 S.E.2d 735 (Ct. App. 2004) (minor chain gaps affect credibility, not admissibility absent tampering)
- State v. Hill, 409 S.C. 50, 760 S.E.2d 802 (2014) (CODIS-related references may create inference of prior record but may be harmless)
- State v. Wiles, 383 S.C. 151, 679 S.E.2d 172 (2009) (exclude relevant evidence if probative value substantially outweighed by unfair prejudice)
- State v. Beaty, 423 S.C. 26, 813 S.E.2d 502 (2018) (courts should avoid language suggesting trial's object is to "find the truth" because it risks shifting burden of proof)