State v. Curtis, 356 S.C. 622

Summary

The Supreme Court of South Carolina affirmed Kenneth Curtis's convictions for selling urine substitution kits with intent to defraud drug or alcohol screening tests under S.C. Code section 16-13-470. The court held that the indictments were sufficient, the term "drug test" was not impermissibly vague, the challenge concerning cross-examination about pornographic website links was unpreserved and harmless, and the denial of a directed verdict was proper.

Holdings

1. The indictments were sufficient because they alleged that Curtis knowingly and intentionally operated a business selling urine with intent to defraud a drug test, thereby apprising him of the charged offense and the conduct he had to defend against.
2. South Carolina Code section 16-13-470 is not impermissibly vague merely because it does not define the term "drug test" or limit the statute to tests for illegal drug use.
3. The trial court did not commit reversible error by allowing the State to question Curtis about pornographic links accessible through his website.
4. The directed-verdict motion was properly denied because Curtis's appellate argument was not preserved and, alternatively, the State presented ample evidence from which the jury could find intent to defraud a drug test.

Questions Presented

1. Whether the indictments sufficiently alleged that Curtis committed an offense under South Carolina Code section 16-13-470.
2. Whether the term "drug test" in section 16-13-470 was impermissibly vague.
3. Whether the trial court erred by permitting cross-examination concerning pornographic links accessible through Curtis's website.
4. Whether the trial court erred by denying Curtis's motion for a directed verdict.

Disposition

affirmed