State v. Benton
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The Supreme Court of South Carolina affirmed the decision by the court of appeals in the case of Tommy Lee Benton, who was convicted for the murder of Charles Bryant Smith, two counts of first-degree burglary, one count of first-degree arson, and one count of third-degree arson. Benton's first trial was declared a mistrial due to his failure to disclose his alibi, which he intended to support via his great-grandmother's testimony. Benton claimed that his second trial and ensuing convictions were barred by double jeopardy. The court, however, found that the mistrial was declared due to "manifest necessity," hence, there was no double jeopardy violation.
Benton also argued against the admissibility of gruesome crime scene photographs and certain text and Facebook messages. The court upheld the trial court's decision, asserting that the photographs provided important context to the testimony and other key evidence. The court noted that while the photographs were disturbing, any error in admitting them was harmless as they did not significantly contribute to the verdict. The court also affirmed the admissibility of the text and social media messages.
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