State v. Saltz, 346 S.C. 114

Summary

The South Carolina Supreme Court reviewed Michael Paul Saltz's murder conviction and held that the trial court committed reversible error in admitting a prior consistent statement and irrelevant or prejudicial evidence. The court also held that the defendant was improperly denied the opportunity to present corroborating testimony concerning a defense witness's prior consistent statement, while upholding the admission of his statements to police as voluntary and the limitation on a proposed bias-related cross-examination. The conviction was reversed and a new trial was ordered.

Holdings

1. Questioning a witness about a prior inconsistent statement, without an express or implied charge of recent fabrication or improper influence or motive, does not satisfy Rule 801(d)(1)(B), SCRE, and does not permit admission of the witness's prior consistent statement.
2. When the State charges a defense witness with recent fabrication and improper motive, Rule 801(d)(1)(B), SCRE, permits the defense to introduce a prior consistent statement made before the alleged fabrication or motive arose, absent a valid basis for exclusion.
3. Evidence that a defendant was absent from school on a date not shown to have any significance to the charged homicide is irrelevant, and testimony concerning a witness's emotional reaction to the victim's disappearance is inadmissible when it does not make any consequential fact more or less probable and serves primarily to arouse jury sympathy or prejudice.
4. The trial court properly excluded a proposed question asking a witness whether she would choose loyalty to her friend or protection of her son because the question did not elicit a fact tending to show bias and was inappropriate under the circumstances.
5. The trial court properly admitted Saltz's statements because the State established that he received Miranda warnings, knowingly and intelligently waived his rights, and made the statements voluntarily under the totality of the circumstances.
6. The trial court properly denied the directed-verdict motion because circumstantial evidence, viewed in the light most favorable to the State, was sufficient to establish the corpus delicti of murder and support submission of the case to the jury.

Questions Presented

1. Whether the trial court improperly admitted a prior consistent statement of prosecution witness Sydney Johnston when the defense had challenged only the accuracy of her memory through questioning about a prior inconsistent statement.
2. Whether the trial court improperly excluded testimony from Buddy Hancock concerning a prior consistent statement by defense witness Tina Ashford after the State had charged Ashford with recent fabrication and improper motive.
3. Whether the trial court improperly admitted Saltz's school attendance record and testimony concerning a witness's emotional reaction to evidence about the victim.
4. Whether limiting cross-examination of Shasta Mengedoht violated Saltz's right to confront witnesses or improperly restricted inquiry into bias.
5. Whether Saltz's statements to police were involuntary under Miranda and due process principles.
6. Whether the State presented sufficient evidence of the corpus delicti of murder to withstand Saltz's motion for a directed verdict.

Disposition

reversed