State v. Blurton
537 S.E.2d 291, 342 S.C. 500, 2000 S.C. App. LEXIS 151 (2000)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Evidence offered not for its truth but to show its effect on a defendant's state of mind is not hearsay and is admissible if relevant to corroborate a defense of lacking criminal intent.
Facts:
- James Mayfield, an assistant manager at an Orangeburg Wal-Mart, allegedly recruited Gregory R. Blurton, who did electrical work for the store, to assist in a covert CIA operation codenamed 'Operation Double White'.
- Mayfield, who claimed to be a former Navy SEAL, told Blurton the operation required a 'staged' robbery of the Wal-Mart to establish Blurton's criminal credentials for infiltrating a drug cartel.
- On April 6, 1997, Blurton entered the Wal-Mart and, using a gun provided by Mayfield, demanded money from the cash office from employees Brandon Beckman and Brenda Arant.
- Blurton took $8,500, a fraction of the total cash available, believing he was following Mayfield's instructions.
- After leaving the office, Blurton forced Beckman outside at gunpoint.
- In the parking lot, Blurton confronted a female customer, whom he believed was a CIA contact, and took her car keys and vehicle.
- Blurton then led police on a high-speed chase, which he claimed was part of the staged operation, as he was waiting for the CIA to intervene on his behalf.
Procedural Posture:
- The State of South Carolina prosecuted Gregory R. Blurton in a state trial court.
- At trial, Blurton argued he lacked criminal intent, but the trial court excluded several pieces of evidence offered to support this defense, including taped conversations and newspaper articles.
- A jury convicted Blurton of two counts of armed robbery, kidnapping, grand larceny of a motor vehicle, and failure to stop for a blue light.
- The trial court sentenced Blurton to three concurrent life sentences and additional prison terms.
- Blurton, as the appellant, appealed his convictions to the Court of Appeals of South Carolina, an intermediate appellate court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a trial court commit reversible error by excluding relevant, non-hearsay evidence offered by a defendant to corroborate their claim of lacking criminal intent, thereby denying the defendant the right to present a complete defense?
Opinions:
Majority - Cureton, Judge
Yes. A trial court commits reversible error by excluding relevant evidence that is critical to a defendant's claim of lacking criminal intent, as such exclusion denies the defendant's due process right to present a complete defense. The trial court improperly excluded several key pieces of evidence as hearsay. The taped conversations between Blurton and Mayfield, testimony that others believed Mayfield was a Navy SEAL, and newspaper articles about Mayfield's fictional past were not offered to prove the truth of the matter asserted (i.e., that Mayfield was a CIA agent or a Navy SEAL). Instead, they were offered for the non-hearsay purpose of showing their effect on Blurton's state of mind and to corroborate his testimony that he genuinely believed he was acting as a government operative. This evidence was highly relevant to his defense that he lacked the requisite criminal intent for the charged offenses. The cumulative effect of these evidentiary errors, combined with the prosecutor's improper closing argument calling Blurton a liar, deprived him of a fair trial, necessitating a reversal of his convictions.
Analysis:
This case reinforces the critical distinction between hearsay and evidence offered for a non-hearsay purpose, such as proving the listener's state of mind. The court's decision emphasizes that a defendant's due process right to present a complete defense requires the admission of relevant evidence that corroborates their claimed mental state, even if the defense itself seems outlandish. This precedent is significant for cases where a defendant's subjective belief is a central element of the defense, establishing that the jury must be allowed to hear evidence that makes such a belief more or less plausible. It clarifies that the credibility of such a defense is for the jury to decide, not for the court to foreclose through evidentiary rulings.
