State v. Bryant, 390 S.C. 638

Summary

The Supreme Court of South Carolina affirmed Stephen Corey Bryant’s convictions and sentences, including a death sentence for murder committed during an armed robbery. The court held that excluding testimony from Bryant’s aunt about her own sexual abuse did not warrant reversal because experts had presented evidence of the intrafamilial abuse, and it upheld the sentence after mandatory proportionality review.

Holdings

1. The trial court did not abuse its discretion in excluding the aunt's direct testimony concerning her own abuse because the evidence was irrelevant to Bryant's mitigation case, and Bryant was not prejudiced because his mental-health and social-history experts were permitted to testify about the intrafamilial sexual abuse underlying their opinions.
2. The death sentence was not imposed as a result of passion, prejudice, or another arbitrary factor, and was neither arbitrary nor capricious.

Questions Presented

1. Whether the trial court abused its discretion by refusing to allow Bryant's aunt to testify that she had been sexually abused by Bryant's grandfather as part of Bryant's mitigation evidence.
2. Whether Bryant's death sentence was arbitrary, capricious, or the product of passion, prejudice, or another arbitrary factor under mandatory proportionality review.

Disposition

affirmed