Supreme Court of South Carolina
The State, Respondent v. Luzenski Allen Cottrell, Appellant
December 20, 2017421 S.C. 622
Summary
The South Carolina Supreme Court affirmed Cottrell's murder conviction and death sentence, holding that the trial judge did not abuse discretion in removing appointed counsel, qualifying jurors, excluding detective testimony, giving the jury instruction on malice, or withholding the numerical split of the jury’s note. Justice Few, concurring, agreed with the result but argued the trial court lacked discretion to remove counsel without specific findings and that nondisclosure of the jury note was error, though harmless.