South Carolina v. Rice
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Appellant Jarmel Rice was charged as a juvenile when he was fifteen years old for a series of violent crimes. Following a contested waiver from family court to general sessions court, Appellant pled guilty to three counts of armed robbery and one count of assault with intent to kill and received a sentence of eleven years in prison, with many other charges dismissed. In pleading guilty, Appellant raised no objection to the family court waiver. On appeal to the Supreme Court, Appellant sought to resurrect his family court constitutional challenge to the waiver as violative of "Apprendi v. New Jersey," (530 U.S. 466 (2000)). Because South Carolina permits only unconditional guilty pleas and no jurisdictional claim was presented, the Supreme Court concluded Appellant waived his right to assert a claim based on "Apprendi.": "[b]eyond Appellant's failure to assert a jurisdictional argument on appeal . . . Appellant's Apprendi challenge fails on the merits." The Court held that Apprendi is not applicable to a family court juvenile waiver hearing, for a decision whether to waive a juvenile to general sessions court in no manner determines the juvenile's guilt, innocence, or punishment - it merely determines the forum in which the case is to be tried.
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