State v. Harry

Summary

The South Carolina Supreme Court affirmed the conviction of Kareem Harry for murder under the accomplice-liability principle that the hand of one is the hand of all. The court held that the State presented sufficient evidence for the case to reach the jury, including evidence that Harry recruited armed accomplices to help retrieve his television and participated in a confrontational encounter during which an accomplice shot the victim. The court reviewed the denial of Harry’s motion for a directed verdict under the standard requiring the evidence and reasonable inferences to be viewed in the light most favorable to the State.

Holdings

1. The State presented sufficient evidence that Harry was present at the shooting pursuant to a prior arranged plan to undertake an illegal act, if necessary, to retrieve his television. The evidence therefore supported submission of the murder charge to the jury and the denial of Harry's directed verdict motion was proper.

Questions Presented

1. Whether the State presented substantial circumstantial evidence that Harry participated in a prior arranged plan to undertake an illegal act, if necessary, to retrieve his television, thereby supporting murder liability under the hand-of-one-is-the-hand-of-all theory.
2. Whether the trial court properly denied Harry's motion for a directed verdict.

Disposition

affirmed