South Carolina v. Manning
Annotate this CaseRespondent Theodore Manning was charged with murder following the death of his girlfriend, Mikki McPhatter. The victim died after being shot in the back of the head in Respondent's home. It was undisputed that the victim was unarmed. Another of Respondent's girlfriends, Kendra Goodman, led police to the victim's abandoned and burned vehicle, where her charred skeletal remains were discovered in the trunk. Respondent claimed self-defense. At a pre-trial hearing, Respondent's counsel relied upon Respondent's statement to police, introduced as an exhibit by the State, to support his immunity claim. In the statement, Respondent maintained he had taken a gun away from the victim during an argument, but ultimately "pulled the trigger to show her to stop playing." After considering Respondent's statement to police and hearing arguments from counsel for both sides, the trial court denied Respondent's pretrial motion for immunity. The matter then proceeded to a jury trial, where respondent was convicted of voluntary manslaughter and sentenced to thirty years in prison. Respondent appealed, and the court of appeals found, inter alia, that the trial court was required to grant Respondent a full evidentiary hearing prior to determining whether the immunity provision applied, and therefore the court of appeals remanded the case for a full hearing. The Supreme Court granted the State's petition for a writ of certiorari to decide whether the appellate court's judgment was made in error. After review, the Supreme Court concluded respondent received the pre-trial determination he was entitled to under South Carolina law, and the trial court did not abuse its discretion in making that ruling without first conducting a full testimonial evidentiary hearing. As such, the Court reversed the Court of Appeals.
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