Russell Earley, Respondent v. State of South Carolina, Petitioner

Summary

The South Carolina Supreme Court reversed the post‑conviction relief court’s order granting relief and reinstated Russell Earley’s conviction and sentence, holding that the PCR court erred in finding a mistrial was the only remedy for the State’s nondisclosure of a Facebook posting and misapplied the Strickland test. Justice Pleicones dissented, arguing the PCR court correctly applied the law and should have been affirmed.