State v. Knuckles, 354 S.C. 626

Summary

The Supreme Court of South Carolina held that an indictment charging second-offense driving under the influence sufficiently conferred subject matter jurisdiction on the circuit court. The indictment did not need to expressly allege that the defendant's faculties were materially and appreciably impaired because that language described the required level of proof and did not alter the corpus delicti of the offense.

Holdings

1. The indictment was sufficient to confer subject matter jurisdiction because it alleged the necessary elements of the DUI offense and apprised Knuckles of the charge he had to meet.
2. The statutory inclusion of the level or standard of proof described as materially and appreciably impaired did not change the corpus delicti of DUI.

Questions Presented

1. Whether the indictment was insufficient to confer subject matter jurisdiction because it did not expressly allege that Knuckles's faculties were materially and appreciably impaired.
2. Whether the statutory phrase materially and appreciably impaired altered the corpus delicti of DUI or constituted an additional element that had to be specifically alleged in the indictment.

Disposition

reversed