State v. Rowell, 5832

Rowell's truck collided head-on with Cockrell's truck; Cockrell died and Sanders suffered great bodily injury. Rowell was indicted for felony DUI (death) and felony DUI (great bodily injury).
Two hospital blood samples were collected: Sample A drawn on arrival (alleged BAC .175–.189); Sample B drawn after surgery and substantial transfusions (alleged BAC .09).
Medical records and witness testimony showed timing discrepancies and incomplete recollection about who transported Sample A to the lab; the State offered an audit trail and hospital testimony to establish custody.
Rowell received large volumes of blood and fluids during treatment (over 150% of blood volume per defense expert) and Sample B contained Benadryl and acetones, which defense experts said undermined its reliability.
During voir dire, Juror 164 did not disclose pending criminal charges; Rowell learned of the arrest post-trial but did not subpoena the juror for a new-trial hearing.
The jury convicted Rowell; the trial court admitted both samples (finding methodology reliable), denied a new trial based on juror nondisclosure, and the Court of Appeals affirmed.

Issue	Plaintiff's Argument (Rowell)	Defendant's Argument (State)	Held
1. Chain of custody for Sample A	Time discrepancies and an uncalled witness (Evans) show chain broke; Sample A might not be Rowell's blood	Hospital audit trail, testimony identified who drew/handled the sample; chain established as far as practicable	Affirmed: trial court did not abuse discretion; minor discrepancies go to weight, not admissibility
2. Reliability of Sample A after transfusion (≈50% replaced)	Transfusion before Sample A renders BAC unreliable	Issue not timely raised at trial; therefore unpreserved for appeal	Not reviewed on merits; issue unpreserved
3. Reliability of Sample B after extensive transfusions (≈150% replaced) and presence of Benadryl/acetones	Massive dilution and unexpected drugs/metabolites make Sample B scientifically meaningless	Testing methodology was reliable; even if Sample B unreliable, other evidence proves intoxication	Affirmed: any error admitting Sample B was harmless in light of other evidence (Sample A, open containers, smell)
4. Failure to hold evidentiary hearing for juror nondisclosure	Trial court should have held hearing to determine intentional concealment and possible bias	Rowell failed to subpoena juror or produce the juror's testimony; record insufficient to show intentional concealment	Affirmed: no relief because defendant failed to develop record; court requires juror testimony to overturn verdict when needed

State v. Pulley, 423 S.C. 371 (2018) (chain-of-custody for fungible items must be established as far as practicable)
State v. Hatcher, 392 S.C. 86 (2011) (chain-of-custody rule flexible; not every handler must testify)
S.C. Dep't of Soc. Servs. v. Cochran, 364 S.C. 621 (2005) (chain-of-custody need only be shown as practicable per circumstances)
United States v. De Larosa, 450 F.2d 1057 (3d Cir. 1971) (factors for reviewing chain-of-custody: nature of item, preservation circumstances, likelihood of tampering)
State v. Patterson, 425 S.C. 500 (2019) (minor chain discrepancies affect credibility/weight, not admissibility)
State v. Johnson, 318 S.C. 194 (1995) (discrepancies in custody timelines go to credibility, not per se inadmissibility)
State v. Dunbar, 356 S.C. 138 (2003) (issues not raised and ruled on at trial are not preserved for appeal)
State v. Woods, 345 S.C. 583 (2001) (new trial required only where juror intentionally concealed information that would support a cause challenge or affect peremptory use)