South Carolina v. Niles
Annotate this CaseRespondent Richard Niles, Jr. was convicted of murder, armed robbery, and possession of a weapon during the commission of a violent crime. Respondent, his girlfriend and Ervin Moore met the victim, James Salter, in a store parking lot intending to purchase drugs. The evidence at trial focused on whether respondent was the aggressor in the encounter. On the facts entered into evidence at trial, the trial court instructed the jury on the law of murder and self-defense, but refused Niles's request to instruct the jury on voluntary manslaughter, reasoning that the evidence showed Niles was either guilty of murder or he was not guilty of any crime based on his claim of self-defense. The court of appeals reversed Niles's murder conviction and remanded the case for a new trial, finding the evidence compelled a jury instruction on the lesser-included offense of voluntary manslaughter. The Supreme Court granted the State's for certiorari review to consider the State's argument that the court of appeals erred in determining Niles was entitled to a jury instruction on voluntary manslaughter because there was no evidence at trial that Niles acted in the sudden heat of passion. The Supreme Court held that the evidence did not warrant a voluntary manslaughter charge, and reversed the court of appeals.
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