On Wednesday, January 6th, the South Carolina Supreme Court published one opinion, State v. Bennett.
Kevin Tyrone Bennett was convicted of petit larceny, malicious injury to property, and second degree burglary. He was sentenced to ten years’ imprisonment for each offense, to be served concurrently. The court of appeals reversed his convictions, finding the trial court erred in denying Bennett’s motion for directed verdict because the State failed to present substantial circumstantial evidence of guilt.
This Court reversed the court of appeals’ decision and took the opportunity to clarify the framework of a court’s inquiry in determining whether substantial circumstantial evidence exists to require the denial of a directed verdict.” The Court opined that in ruling on a directed verdict motion where the State relies on circumstantial evidence, the court must determine whether the evidence presented is sufficient to allow a reasonable juror to find the defendant guilty beyond a reasonable doubt. Accordingly, the Court held that the trial court did not err in denying Bennett’s motion for directed verdict because examining the evidence in the light most favorable to the State, the evidence could have induced a reasonable juror to find Bennett guilty.