South Carolina v. Niles
Annotate this CaseThis case stemmed from the shooting death of James Salter (the victim) in a Best Buy parking lot in Myrtle Beach. It was undisputed that defendant Richard Niles, Jr., his fiancé, Mokeia Hammond, and Ervin Moore met the victim at the parking lot to purchase marijuana from him. Defendant was convicted of murder, armed robbery, and possession of a weapon during the commission of a violent crime. The trial court instructed the jury on the law of murder and self-defense, but refused defendant's request to instruct the jury on voluntary manslaughter, reasoning that the evidence showed defendant 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 defendant'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. Specifically, the court of appeals found there was evidence of sufficient legal provocation based on defendant's testimony that he shot at the victim only after the victim began shooting first. The Supreme Court granted the State's petition for a writ of certiorari to consider the State's argument that the court of appeals erred in determining defendant was entitled to a jury instruction on voluntary manslaughter because there was no evidence at trial that defendant acted in the sudden heat of passion. After review, the Supreme Court reversed: defendant's own testimony did not establish that he was overtaken by a sudden heat of passion such that he had an uncontrollable impulse to do violence. "Rather, Niles testified that he did not want to hurt the victim; that he shot with his eyes closed; that he was merely attempting to stop the victim from shooting; and that when he shot his gun, he was thinking of Hammond rather than of perpetrating violence upon the victim. In other words, there was nothing sudden about Niles's decision to shoot the victim. Thus, we hold that the evidence did not warrant a voluntary manslaughter charge."
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