Supreme Court of South Carolina
State v. Robert Lee Miller, III
September 13, 2023
Summary
The court affirmed the admission of a fifteen-year-old defendant's confession to SLED agents, holding that the confession was voluntary under the totality of the circumstances and that the defendant understood and voluntarily waived his Miranda rights. The court clarified that factual findings concerning voluntariness receive review for evidentiary support, while the ultimate legal determination of voluntariness is reviewed de novo. The court also concluded that any error in admitting the confession would have been harmless beyond a reasonable doubt because three other confessions and substantial corroborating evidence independently established guilt.