State v. Adam Rowell

Syllabus

After a jury convicted Adam Rowell of two felony driving under the influence charges, he discovered one of the jurors, Juror 164, had failed to disclose during voir dire that he had recently been arrested. Armed with this information, Rowell included it among other grounds in his motion for a new trial. Juror 164 was not present at the hearing on the new trial motion. After the hearing, Rowell requested another hearing so Juror 164 could be examined. Although the State consented to the request, the circuit court did not hold a second hearing and instead issued a written order denying Rowell a new trial. Rowell appealed. The court of appeals affirmed, holding the circuit court did not abuse its discretion in failing to conduct an evidentiary hearing with Juror 164. State v. Rowell, 436 S.C. 54, 870 S.E.2d 175 (Ct. App. 2022). We granted certiorari and now reverse.