State v. Butler

Summary

The South Carolina Supreme Court affirmed Beulah Ruth Butler’s convictions for voluntary manslaughter and possession of a firearm or knife during the commission of a violent crime. The court held that the trial court applied the correct standard in denying Butler’s motion for a directed verdict on self-defense because conflicting accounts and other evidence created a jury issue. The court distinguished precedent requiring a directed verdict where uncontroverted facts establish self-defense as a matter of law.

Holdings

1. At the directed-verdict stage, the trial court determines whether evidence exists to create a jury issue; it does not apply the beyond-a-reasonable-doubt burden used when self-defense is submitted to the jury.
2. The trial court properly denied Butler's motion for a directed verdict because the State presented sufficient direct or substantial circumstantial evidence to create a jury issue on self-defense.

Questions Presented

1. Whether the trial court was required to apply a beyond-a-reasonable-doubt standard to the State's burden of disproving self-defense at the directed-verdict stage.
2. Whether the evidence was sufficient to create a jury issue on self-defense and therefore support denial of Butler's motion for a directed verdict.

Disposition

affirmed