State v. Hatcher, 392 S.C. 86

Summary

The Supreme Court of South Carolina held that the State established the chain of custody for drug evidence as far as practicable. The court concluded that every person who handled fungible evidence need not be identified where the evidence and its handling were sufficiently documented and there was no indication of tampering or substitution. The court reversed the Court of Appeals and upheld admission of the evidence.

Holdings

1. The State need not establish the identity of every person who handled fungible evidence in every case; it must establish the chain of custody as far as practicable, and the determination depends on the unique factual circumstances of each case.
2. The trial court did not abuse its discretion by admitting the drug evidence because the State established a sufficient chain of custody and the record provided reasonable assurance that the evidence was the same drug obtained from Hatcher and had not been altered, tampered with, or substituted.

Questions Presented

1. Whether the State established a sufficient chain of custody for the drug evidence despite not identifying or presenting testimony from every person who may have handled it.
2. Whether the trial court abused its discretion by admitting the drug evidence.

Disposition

reversed