State v. Dickerson

Citations: 535 S.E.2d 119; 341 S.C. 391; 2000 S.C. LEXIS 158Docket: 25164

Court: Supreme Court of South Carolina; July 3, 2000; South Carolina; State Supreme Court

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William Oliver Dickerson was convicted of the murder of 83-year-old Mary Middleton and appealed the decision. The Supreme Court of South Carolina upheld the conviction. The victim was last seen alive on May 31, 1996, when she visited a neighbor, Chrisaundra Lockwood, to inform her about a phone call. During this time, Lockwood saw the victim conversing in her backyard with a man in a green hospital shirt, later identified as Dickerson. Another neighbor, Quinnie Gailliard, also recognized Dickerson in the backyard near the victim’s car.

Later that evening, Dickerson asked a friend, Willie Gibbs, for a ride and disclosed that he and a friend had just killed a man, showing Gibbs his bloodstained pants. After an argument, Dickerson left Gibbs’ car and went to his girlfriend Sandra Jenkins' apartment, where he wore a green hospital shirt and pants that were inside out and covered in blood. He claimed to have witnessed a stabbing involving a man and his girlfriend, though he did not disclose his involvement in the murder of Middleton.

The next morning, neighbors found Middleton dead in her home, which had been ransacked. She had suffered 25 stab wounds, leading to her death by blood loss, with the estimated time of death around 8:00 p.m. on May 31, coinciding with when Dickerson was seen with her. The police found no forced entry into the house.

The medical examiner classified the victim's death as an 'overkill' murder, indicating that the injuries inflicted were excessively severe for the victim to have died. Such 'overkill' murders are typically associated with lovers' quarrels or drug-induced states, particularly cocaine use. Investigators found the defendant's fingerprints throughout the victim's home, including on personal items and a car linked to the crime scene. The defendant, who lived nearby and was acquainted with the victim's family, claimed he had never been inside the victim's house. After his arrest, he provided a detailed sworn statement outlining his activities on the day of the murder, including drug use.

During the trial, the defendant sought to redact references to his drug use from his statement, arguing it constituted improper evidence of prior bad acts. The judge allowed the full statement, leading to the defendant's conviction and subsequent appeal based on whether this evidentiary ruling was erroneous. The court held that the drug use evidence was not improper character evidence but was relevant to establishing the defendant's identity as the murderer, as the medical expert noted a correlation between cocaine use and 'overkill' murders. South Carolina law allows the introduction of prior acts to demonstrate motive, intent, or identity, which justified the inclusion of the defendant's drug use in this case.

The cases cited establish that evidence of drug use is admissible only if it has a relevant connection to the crime. In *State v. Smith*, the court ruled that evidence of the defendant's prior cocaine use was inadmissible as it did not demonstrate a relationship to the murder, particularly due to the time lapse between the drug use and the crime. In contrast, the current case allows for the defendant's cocaine use during the murder, as the medical examiner linked it to the murder's "overkill" nature, supporting the argument that the defendant is indeed the murderer.

In *State v. Bolden*, the court found error in admitting evidence of crack cocaine use the night before an armed robbery, citing a lack of logical relevance to the crime. Conversely, in the current case, the medical expert testified that the defendant's cocaine use likely influenced the violent nature of the murder. 

In *State v. Coleman*, the court ruled against admitting evidence of the defendant's social cocaine use, as it lacked relevance to motive and merely portrayed the defendant's bad character. However, in the current case, the defendant's drug use is pertinent to establishing identity rather than attacking character. Thus, the evidence is deemed admissible.

The defendant admitted to being under the influence of drugs during the murder. Unlike in State v. Hough, where prior drug use did not establish motive, the State argues that the defendant's contemporaneous drug use was integral to the murder's nature. Expert testimony links overkill to situations involving drug intoxication, supporting the State's claim that the defendant's state of mind during the crime was influenced by his drug use. The evidence of drug use is deemed clear and convincing, meeting the admissibility standard under State v. Adams, and it is argued to have probative value that outweighs any prejudicial effects, as per Rule 403, SCRE. The evidence was not introduced to show a propensity for crime but to establish a connection between the defendant's drug use and the crime. It is also admissible under the theory of res gestae due to its close temporal relationship with the crime, indicating it was part of the crime's environment. Consequently, the court affirmed the defendant's conviction, with justices concurring.