State v. Rice, 737 S.E.2d 485

Rice, age 15, was charged as a juvenile with multiple violent crimes.
After a contested waiver from family court, Rice’s case was transferred to general sessions court.
Rice pled guilty to three armed robbery counts and one assault with intent to kill; several charges were dismissed.
Rice raised no objection to the family court waiver at the time of pleading.
The appellate issue centered on whether Apprendi applies to the juvenile waiver and whether the guilty plea waived the challenge to the waiver.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Apprendi applies to the family court juvenile waiver.	Rice argues the waiver violates Apprendi, increasing punishment beyond the jury verdict.	SC law permits challenge to waiver; Apprendi does not apply to waiver determinations.	Apprendi does not apply to juvenile waiver determinations.
Does a guilty plea in general sessions waive the right to appeal the family court waiver order?	Rice asserts the guilty plea preserves the right to challenge the waiver.	Guilty plea generally waives nonjurisdictional claims; waiver of the transfer order is valid.	Guilty plea generally waives nonjurisdictional claims; Apprendi issue deemed waived.

Tollett v. Henderson, 411 U.S. 258 (U.S. 1973) (guilty plea waives prior nonjurisdictional claims; attacks must show voluntary and intelligent plea)
State v. Passaro, 350 S.C. 499 (S.C. 2002) (guilty plea waives nonjurisdictional defects and rights invoked pre-plea)
Vogel v. City of Myrtle Beach, 291 S.C. 229 (S.C. 1987) (plea waives nonjurisdictional defenses and constitutional rights pre-plea)
Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (any fact increasing punishment beyond statutory maximum must be juried and proved beyond reasonable doubt)
Oregon v. Ice, 555 U.S. 160 (U.S. 2009) (Apprendi does not apply to predicate findings for consecutive vs concurrent sentencing in some contexts)