State v. Sams
764 S.E.2d 511
S.C.2014Background
- Sams choked Frazier during a fight, lying on top with his arm around Frazier's neck for over ten minutes.
- Frazier stated he could not breathe and asked to be released; 911 was called multiple times.
- Police arrived; Sams initially refused to release the chokehold; officer ordered him to disengage and then handcuffed him.
- Autopsy showed bruises and neck injuries with signs of strangulation; death ruled asphyxiation due to strangulation.
- Sams was indicted for murder; trial court instructed on murder, voluntary manslaughter, and self-defense but not involuntary manslaughter.
- Jury convicted Sams of voluntary manslaughter; appellate courts affirmed; certiorari granted by this Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether involuntary manslaughter instruction was warranted | Sams argued evidence supported involuntary manslaughter under either definition. | Sams contends he acted lawfully (self-defense) or negligently, entitling an involuntary manslaughter charge. | Not entitled; no sufficient evidence of unintentional death or reckless disregard under state law. |
Key Cases Cited
- State v. Tucker, 324 S.C. 155 (1996) (defines involuntary manslaughter elements and negligence standard)
- State v. Byrd, 323 S.C. 319 (1996) (recklessness standard in involuntary manslaughter context)
- State v. Pittman, 373 S.C. 527 (2007) (recklessness and evidentiary standards for lesser-included offenses)
- State v. Smith, 315 S.C. 547 (1994) (definition of criminal negligence and involuntary manslaughter)
- State v. Light, 378 S.C. 641 (2008) (mutual availability of self-defense and involuntary manslaughter charges)
- State v. Pickens, 320 S.C. 528 (1996) (distinguishing self-defense from involuntary manslaughter in defense scenarios)
- State v. Scott, 408 S.C. 21 (Ct.App.2014) (Court of Appeals analysis of self-defense vs. involuntary manslaughter)