The State v. William Mark Brockmeyer (South Carolina 2013)

Summary

The South Carolina Supreme Court affirmed Brockmeyer’s murder and weapons convictions, holding that the trial court did not err in refusing to enforce a subpoena for an anonymous internet commenter, that the admission of chain‑of‑custody evidence did not violate the Sixth Amendment Confrontation Clause, and that the admission of photographs was not reversible error. The Court noted the issues were either not preserved or harmless beyond a reasonable doubt.

Holding

Whether a criminal defendant’s compulsory process right requires a trial court to disclose the identity of an anonymous internet commenter when the information is potentially material to a defense. The trial court’s refusal to enforce the subpoena was not reversible error because the issue was not preserved for appellate review and, even assuming error, the defendant was not prejudiced; the commenter's identity could be obtained from other sources.

Whether the admission of chain‑of‑custody testimony and logs violated the Sixth Amendment Confrontation Clause. The admission did not violate the Confrontation Clause because the chain‑of‑custody statements were non‑testimonial business records, and the evidence was uniquely identifiable, so strict chain‑of‑custody proof was not required.

Whether the admission of photographs of the defendant and a cell‑phone image was reversible error under Rule 403. The photographs were properly admitted; any error was harmless because the photographs were cumulative to other evidence and did not prejudice the defendant.

Whether any error identified was harmless beyond a reasonable doubt. Any alleged error was harmless because the defendant’s own testimony and other evidence established the facts the challenged evidence was offered to prove.

The State v. William Mark Brockmeyer

Summary

Holding

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