State v. Covington

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• finding that a clear and convincing standard need not be applied when juror concealment cannot first be proven under the lesser preponderance of the evidence standard
• requiring a showing of prejudice when a defendant seeks a new trial on the basis of juror misconduct
• stating that when a motion for a new trial is based upon allegations that a juror’s answers on voir dire were incomplete or misleading, the trial judge’s denial of that motion will be affirmed absent a prejudicial abuse of discretion
• adopting Aldret procedure in a case involving alleged intentional concealment during voir dire
• finding evidence of juror misconduct is evaluated under a clear and convincing standard
• “Given the conflicting evidence [regarding whether juror misconduct had occurred], we defer to the sound judgment of the trial judge in resolving a disputed factual issue and, therefore, find no abuse of discretion on his part.”

Source: CourtListener parenthetical corpus (CC0).

Cited by

10 cases in this archive cite this case.

• State v. Zeigler
  Court of Appeals of South Carolina· 2005-03-21· cited 60×
• State v. Galbreath
  Court of Appeals of South Carolina· 2004-06-01· cited 21×
• State v. Coaxum
  Supreme Court of South Carolina· 2014-10-08· cited 16×
• State v. Yarborough
  Court of Appeals of South Carolina· 2005-01-31· cited 11×
• State v. Navy
  Court of Appeals of South Carolina· 2006-07-31· cited 10×
• State v. Guillebeaux
  Court of Appeals of South Carolina· 2004-12-20· cited 9×
• State v. Tucker
  Court of Appeals of South Carolina· 2018-04-18· cited 8×
• Lynch v. Carolina Self Storage Centers, Inc.
  Court of Appeals of South Carolina· 2014-03-26· cited 6×
• Thomas v. People
  Supreme Court of The Virgin Islands· 2014-03-10· cited 5×
• Lynch v. Toys\ R\ Us-Delaware, Inc.
  Court of Appeals of South Carolina· 2007-11-27· cited 4×

Cites

8 cases in this archive are cited by this case.

• State v. Kelly
  Supreme Court of South Carolina· 1998-06-29· cited 68×
• State v. Aldret
  Supreme Court of South Carolina· 1999-01-04· cited 49×
• Johnnie Knowlton v. Greenwood Independent School District
  Fifth Circuit· 1992-04-16· cited 41×
• State v. Grovenstein
  Supreme Court of South Carolina· 1999-06-01· cited 37×
• State v. Smith
  Supreme Court of South Carolina· 1993-12-13· cited 28×
• State v. Salters
  Supreme Court of South Carolina· 1979-08-09· cited 16×
• State v. Smith
  Court of Appeals of South Carolina· 1999-12-06· cited 10×
• Scott v. State
  Court of Criminal Appeals of Texas· 1956-04-04· cited 3×