State v. Scott, 779 S.E.2d 529

Cynthia Nelson was stabbed in the neck and later died after an altercation with Antonio Scott at a Ridgeland apartment; Scott fled but later surrendered.
Scott told police he executed a martial-arts move that caused Cynthia to stab herself; no witness corroborated that account.
At trial Scott did not testify and presented no evidence; the State introduced witness testimony contradicting the self-inflicted-stab story.
The trial court instructed the jury on murder, voluntary manslaughter, and self-defense, but denied Scott’s requested involuntary manslaughter instruction.
The jury convicted Scott of murder; Scott appealed arguing the court should have charged involuntary manslaughter.
The South Carolina Supreme Court affirmed the court of appeals, holding the evidence did not support an involuntary manslaughter charge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence warranted an involuntary manslaughter jury instruction	Scott: his statement that he executed a martial-arts move supports a theory he unintentionally killed Cynthia and thus acted recklessly	State: evidence showed intentional conduct or justified self-defense; no evidence of reckless disregard required for involuntary manslaughter	Court: No—record lacked evidence of criminal negligence/recklessness; trial court did not err in refusing the instruction
Whether self-defense and involuntary manslaughter instructions can coexist here	Scott: jury could infer reckless excess in self-defense justifying involuntary manslaughter	State: self-defense instruction was given; imperfect self-defense is not adopted to convert to involuntary manslaughter	Court: Even if imperfect self-defense were recognized, it would at most support voluntary manslaughter; no basis for involuntary manslaughter here

State v. Sams, 410 S.C. 303 (discusses when lesser-included offense instructions are required and rejects imperfect self-defense as basis for involuntary manslaughter)
State v. Smith, 315 S.C. 547 (trial court may refuse lesser-included instruction when no evidence supports it)
State v. Laney, 367 S.C. 639 (standard of review: courts review legal errors; factual findings upheld absent abuse of discretion)
State v. Pittman, 373 S.C. 527 (refusal to give a proper jury charge is an error of law)
State v. Brayboy, 387 S.C. 174 (defines recklessness for criminal negligence)
Robinson v. State, 308 S.C. 74 (self-defense is a complete defense to criminal charge)