Walker v. State

Summary

The South Carolina Supreme Court considered whether trial counsel rendered ineffective assistance by failing to investigate and interview a potential alibi witness. The court held that the court of appeals improperly disregarded the PCR court’s credibility findings and misapplied the standard governing alibi testimony. It reversed the court of appeals and affirmed the PCR court’s grant of post-conviction relief.

Holdings

1. Trial counsel has a duty to investigate alibi witnesses identified by the defendant, and failing to make some effort to contact such a witness to determine whether the testimony would aid the defense is unreasonable.
2. A PCR applicant may establish prejudice from counsel's failure to investigate an alibi witness when the credited testimony, if true, reasonably could have produced a different trial outcome, even if the testimony is not perfectly precise or unequivocal.
3. An appellate court must apply a limited standard of review to PCR findings and must defer substantially to the PCR court's credibility determinations; it may not reject a supported credibility-based interpretation of alibi testimony merely because the testimony is ambiguous.

Questions Presented

1. Whether trial counsel rendered ineffective assistance by failing to investigate and interview a potential alibi witness identified in Walker's recorded statement.
2. Whether the court of appeals improperly held that Walker was not prejudiced because the potential alibi testimony did not account for his whereabouts with sufficient precision to make commission of the crimes physically impossible.
3. Whether the court of appeals exceeded the limited standard of review applicable to the PCR court's factual and credibility findings.

Disposition

reversed