State v. Mack Adams Gaines

Summary

The South Carolina Court of Appeals affirmed Mack Adams Gaines's conviction and twenty-year sentence for abuse or neglect of a vulnerable adult resulting in death. The court held that sufficient evidence supported submitting to the jury whether the victim became a vulnerable adult after her fall and whether Gaines acted as her caregiver under the Omnibus Adult Protection Act.

Holdings

1. The evidence was sufficient to submit to the jury whether the victim was a vulnerable adult after her fall because her inability to get up or provide nourishment or heat indicated that her physical condition substantially impaired her ability to provide for her own care or protection.
2. The evidence was sufficient to submit to the jury whether Gaines was a caregiver because he provided care to the victim after her fall, even if without compensation and even if he was merely a roommate or household member.

Questions Presented

1. Whether the evidence was sufficient to submit to the jury the question of whether the victim was a vulnerable adult under the Omnibus Adult Protection Act.
2. Whether the evidence was sufficient to submit to the jury the question of whether Gaines was a caregiver under the Act.

Disposition

affirmed