Rutland v. State

Summary

The South Carolina Supreme Court reversed the denial of Fred R. Rutland’s application for post-conviction relief. The court held that trial counsel was ineffective for failing to impeach the State’s key witness with prior inconsistent statements concerning whether the victim was armed, and that the omission prejudiced Rutland because the witness’s credibility was central to his self-defense claim.

Holdings

1. Trial counsel's failure to cross-examine the State's only disinterested eyewitness about prior inconsistent statements was deficient and prejudicial under Strickland because there was a reasonable probability that effective impeachment would have changed the outcome of the trial or undermined confidence in the verdict.

Questions Presented

1. Whether trial counsel was ineffective for failing to cross-examine the State's key witness regarding her prior inconsistent statements that the victim was armed.
2. Whether trial counsel was ineffective for failing to preserve for appellate review the trial court's refusal to charge the jury on the defense of others.

Disposition

reversed