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When ruling on a motion for a directed verdict, the trial court is concerned with the existence or nonexistence of evidence, not its weight. A defendant is entitled to a directed verdict when the State fails to produce evidence of the offense charged. On appeal from the denial of a directed verdict in a criminal case, an appellate court must view the evidence in the light most favorable to the State. If there is any direct or any substantial circumstantial evidence reasonably tending to prove the guilt of the accused, the appellate court must find that the issues were properly submitted to the jury. Nevertheless, an appellate court is not required to find that the evidence infers guilt to the exclusion of any other reasonable hypothesis. The lens through which an appellate court considers circumstantial evidence when ruling on a directed verdict motion is distinct from the analysis performed by the jury. Accordingly, in ruling on a directed verdict motion where the State relies on circumstantial evidence, the appellate court must determine whether the evidence presented is sufficient to allow a reasonable juror to find the defendant guilty beyond a reasonable doubt.
Douglas Paul noticed a strange car in the driveway of his mother’s home. Police officers responded to Paul’s call, and in the course of which, defendant Teresa Davis was arrested. Police officers also found drugs in defendant’s car. A grand jury indicted Davis for first-degree burglary and PWID methamphetamine, second offense. At the beginning of trial, defendant moved to sever her charges, arguing the offenses were not closely related in kind or character. The trial court denied defendant's motion, finding both charges required the same witnesses. At the close of the State's case, the trial court instructed the jury the parties stipulated defendant had two prior burglary convictions. Defendant moved for a directed verdict on the first-degree burglary charge, arguing the State failed to show there was an "occupant or inhabitant against whom the offense could have been committed"; therefore, the home did not qualify as a dwelling for purposes of first-degree burglary. Additionally, defendant moved for a directed verdict on the PWID charge, arguing the State failed to show she had control over the drugs found in the car because the police found her on the roof of the home. In response, the State contended it presented circumstantial evidence showing the drugs were in defendant’s control because the police found the methamphetamine in a bag next to defendant’s purse in a car that she admitted to driving. The trial court denied defendant's motion, finding it was a question for the jury whether defendant had control or possession of the drugs. At the close of trial, the jury found defendant guilty of both charges as indicted. Defendant appealed.
The court held that the defendant suffered no prejudice and the trial court did not abuse its discretion in refusing to sever the indictments because the joinder of her first-degree burglary and possession with intent to distribute (PWID) methamphetamine offenses was proper. Because her arrest for PWID methamphetamine arose out of the police's inventory of the car at the scene of the burglary investigation, the offenses originated from the same chain of events and required the same witnesses; Furthermore, the trial court properly refused to direct a verdict on (PWID) methamphetamine under S.C. Code Ann. § 44-53-370(c) (2018) because the car found in the driveway of the burglary scene contained defendant’s driver’s license, methamphetamine, and a digital scale, spoon, and baggies, indicating the methamphetamine was for distribution rather than personal use. Accordingly, the judgment was affirmed.