South Carolina v. Jenkins
Annotate this CaseDuring her commute to work, H.M., the victim, frequently passed by a local grocery store and casually greeted the people loitering outside, many of whom lived in the area and often gathered there. Although the victim did not know any of these people beyond exchanging a passing greeting, she came to learn that one of the people with whom she exchanged pleasantries was nicknamed "Black." Black followed H.M. home one day, forcibly entered her apartment, beat and raped her, threatening to kill her if she told anyone of the incident. The victim ultimately did call police, and "Black" was revealed to be Respondent Daniel Jenkins. The nurse conducting the rape found semen on vaginal and rectal swabs taken from the victim, as well as on various clothing and bodily swabs. A forensic DNA analyst developed a DNA profile from the rape examination swabs, and compared that profile to Respondent's DNA profile. The DNA profiles matched. Respondent moved to suppress the DNA evidence, arguing that the affidavit did not establish probable cause. The trial court denied the motion to suppress. Ultimately, a jury convicted Respondent of CSC-First. Because of Respondent's two prior convictions for CSC-First and carjacking, both of which are "most serious offenses" under section 17-25-45(C)(1) of the South Carolina Code, the trial court imposed a mandatory sentence of life in prison without the possibility of parole. After its review, the court of appeals held that the affidavit in support of the warrant did not establish probable cause because it contained only conclusory statements; failed to set forth the source of the facts contained therein; lacked any information allowing the Magistrate to make a credibility determination regarding the source of the information; and that the affidavit was defective because it did not contain any indication that the police had obtained DNA evidence from the rape examination, and thus it did not establish that Respondent's DNA would have been relevant to the investigation. The court of appeals concluded that admitting the DNA evidence was not harmless error because it bolstered the victim's credibility regarding two critical facts: that Respondent was her attacker, and that the sexual intercourse was not consensual. Despite reversing the trial court's admission of the DNA evidence, the court of appeals did not order a new trial, but instead remanded the case for an evidentiary hearing in response to the State's argument that Respondent's DNA would have been inevitably discovered regardless of the defective search warrant. The Supreme Court reversed the court of appeals. Notwithstanding the DNA evidence, there was abundant, independent evidence in the record from which the jury could have found Respondent guilty. Accordingly, contrary to the court of appeals' assertion, the Court held that this case was not dependent on the credibility of the victim and Respondent, with the DNA evidence serving as the only physical evidence that Respondent committed the assault.
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