State v. Williams, 733 S.E.2d 605

Williams killed his brother during an incident at the victim's house around midnight; the victim was unarmed and Williams claimed fear for his life.
Eyewitnesses (Holbert and Kelly) described Williams arriving with a shotgun and threatening the victim over money, leading to the shooting.
Williams testified he feared the victim would shoot him and that Kelly threw a loaded shotgun to him during the retreat.
Williams sought to admit toxicology evidence showing the victim's intoxication; the circuit court excluded it but allowed a proffer.
The circuit court denied instructions on self-defense and accident but granted voluntary manslaughter; Williams was convicted of voluntary manslaughter.
The court of appeals reversed, remanding for a new trial, on the grounds that self-defense and accident jury instructions were improperly denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Self-defense instruction requested	Williams entitled to self-defense instruction based on imminent danger	Court correctly refused; no applicable self-defense theory supported	Reversible error; self-defense instruction required
Accident instruction requested	Evidence raised jury question whether shooting was accidental while defending	Accident not warranted given asserted self-defense theory	Reversible error; accident instruction required

State v. Day, 341 S.C. 410 (2000) (entitled to self-defense instructions when evidence supports)
State v. Dickey, 394 S.C. 491 (2011) (elements of self-defense and fault)
State v. Wiggins, 330 S.C. 538 (1998) (state must disprove self-defense beyond reasonable doubt)
State v. Burriss, 334 S.C. 256 (1999) (accident and self-defense can be non-mutually exclusive)
State v. Chatman, 336 S.C. 149 (1999) (excusable homicide by accident requires due care and lawful act)
State v. Light, 378 S.C. 641 (2008) (self-defense and involuntary manslaughter not mutually exclusive with evidentiary context)