South Carolina v. Samuels
Annotate this CaseDefendant Myron Samuels was romantically involved with two women, Patricia Speaks and Carla Daniels, among others, but told each woman he was involved with her alone. Eventually, Speaks and Daniels learned of the other's relationship with Samuels. Daniels traveled to Speaks' home in Columbia, suspecting Samuels was there and wanting to confront him. Samuels was there, and after Daniels entered the home, she and Speaks began to discuss their situation. Speaks informed Daniels that Samuels was romantically involved with two additional women and that she had copied their telephone numbers from his phone. They then decided to call the other women in Samuels' presence, presumably to tell the others of "the health dangers inherent in Samuels' duplicity." While Daniels was speaking to one of the other women on the phone, she felt something touch her forehead. She looked up to see Samuels holding the barrel of Speaks' pistol against her forehead. Speaks began screaming, and Samuels then turned to her and threatened her with the gun. Samuels then fled from the home, and when Speaks ran after him to retrieve her pistol, Samuels hit her, knocking her to the ground. The women then called the police. Samuels was indicted for one count of assault with intent to kill. He challenged his conviction and sentence on the grounds the indictment was duplicitous. Because of the distinct risks created by duplicitous indictments, the Supreme Court held that an indictment is defective and entitles a defendant to relief if it is duplicitous, providing it results in prejudice to the defendant. Although the Court agreed the indictment was duplicitous, the Court found that Samuels was not prejudiced and accordingly affirmed his conviction and sentence.
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