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

Summary

The South Carolina Supreme Court reversed the post‑conviction relief court and reinstated Russell Earley’s conviction and sentence, holding that the State’s nondisclosure of a non‑impeaching Facebook post did not require a mistrial and that the PCR court erred in finding materiality and prejudice. The Court affirmed that Rule 5 disclosure obligations do not automatically mandate a mistrial and that other sanctions are available. A dissent argued the PCR court applied the correct standard and should have affirmed the relief.