The State v. Ricky Lee Blackwell (South Carolina 2017)

Summary

The South Carolina Supreme Court affirmed Ricky Lee Blackwell’s murder convictions and death sentence, holding that the trial court’s pre‑trial Atkins determination, jury selection, Batson analysis, denial of privileged mental‑health records, exclusion of chaplains’ notes, and penalty‑phase instructions were all within the bounds of the law or harmless error. The Court also adopted a procedural rule for handling privileged mental‑health records and clarified the burden of proof for mental‑retardation claims in the penalty phase. Justice Pleicones dissented, arguing Blackwell is mentally retarded and that the trial court erred on several evidentiary issues, while Justice Few concurred except for the analysis of the mental‑health‑record issue.

Holding

Pre‑trial Atkins determination. The trial court’s finding that Blackwell was not mentally retarded was upheld because it was supported by the evidence and not against the preponderance of the evidence.

Juror qualification and Batson challenge. The trial court did not err in qualifying Juror 43 nor in rejecting Blackwell’s Batson claim; the State’s reasons for striking the African‑American jurors were not pretextual.

Use of privileged mental‑health records. The trial court’s refusal to consider the records in camera and to admit them at trial was error, but the error was harmless and did not require reversal.

Admission of chaplains’ notes. The exclusion of the chaplains’ notes was error but harmless because the evidence was cumulative to other mitigation evidence.

Penalty‑phase jury instructions on mental retardation. The trial court correctly instructed that the State bears the burden of proving aggravating circumstances and that the defendant bears the burden of proving mental retardation by a preponderance of the evidence.

The State v. Ricky Lee Blackwell

Summary

Holding

Cited authorities

Cited by