State v. Singley, 709 S.E.2d 603

Singley inherited a 12.5% interest in the home; mother owned 75% and his brother 12.5%.
Singley continued to reside in the house until age in the early twenties, then returned in April 2005 and was later ousted by his mother.
In October 2005, Singley allegedly entered his mother's home at about 2:30 a.m. through a back window, after which he threatened and restrained her during a robbery.
Singley was indicted for first degree burglary, armed robbery, and kidnapping; he moved for a directed verdict on all charges.
The circuit court denied the motion; a jury convicted him of burglary and armed robbery but acquitted kidnapping; the court imposed consecutive life-without-parole sentences.
The Court of Appeals affirmed the burglary conviction, holding that the mother, not Singley, possessed the dwelling at the time of the incident.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does ownership preclude burglary conviction as a matter of law?	Singley: ownership insulates entry; no consent impediment exists.	State: possession and totality of circumstances determine license to enter; ownership alone is not dispositive.	Ownership not dispositive; jury must assess possession and sanctity of the home.

State v. Clamp, 80 S.E.2d 918 (1954) (burglary focuses on possession, not ownership)
State v. Alford, 140 S.E. 261 (1927) (victim need not be owner; occupant/possessor suffices)
State v. Trapp, 17 S.C. 467 (1882) (burglary protects possession and sanctuary of the home)
State v. Coffin, 502 S.E.2d 98 (1998) (possession rights can depend on others; guest vs owner context)
Watson v. Little, 79 S.E.2d 384 (1953) (tenants in common possess equal right to possess whole; ownership not determinative)
State v. Brooks, 283 S.E.2d 830 (1981) (dwelling security and occupant rights central to burglary analysis)