The STATE, Petitioner, v. Harold D. KNUCKLES, Respondent

Supreme Court of South Carolina2003-06-23No. No. 25667

354 S.C. 626583 S.E.2d 51

Summary · law.co

Holding. The Supreme Court reversed the Court of Appeals' decision, holding that the indictment was sufficient to confer subject matter jurisdiction on the circuit court because it alleged the essential elements of the offense and adequately informed the defendant of the charges against him.

Harold Knuckles pleaded guilty to a second-offense driving under the influence charge. The Court of Appeals had vacated his conviction, finding that the indictment lacked sufficient detail because it did not explicitly allege that Knuckles' faculties were "materially and appreciably impaired" as required by the governing statute. The Supreme Court disagreed, holding that an indictment need only charge the essential elements of the offense and inform the defendant of what to expect; it need not include every specific detail mentioned in the statute. The court reasoned that the basic elements of DUI—driving a vehicle within the state while under the influence—were adequately alleged, and that the statutory standard regarding impairment goes to proof at trial rather than to the sufficiency of the charging document itself.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether an indictment must explicitly allege the statutory standard of "materially and appreciably impaired" to be sufficient
The distinction between the corpus delicti of DUI and the level or standard of proof required at trial
Sufficiency of an indictment to confer subject matter jurisdiction

Procedural posture

The Supreme Court granted certiorari to review the Court of Appeals' decision vacating the defendant's DUI conviction on grounds of insufficient indictment.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

majority opinion

Justice BURNETT:

We granted certiorari to review the Court of Appeals’ decision in State v. Knuckles, 348 S.C. 593, 560 S.E.2d 426 (Ct.App.2002). We reverse.

FACTS

The relevant facts are uncontested. Harold D. Knuckles (“Knuckles”) pled guilty to a 1998 indictment for driving under the influence, second offense, in violation of S.C.Code Ann. § 56-5-2930. The Court of Appeals held the indictment insufficient to confer subject matter jurisdiction and vacated Knuckles’ conviction.

ISSUE

Did the Court of Appeals err in ruling the indictment did not confer subject matter jurisdiction?

DISCUSSION

Knuckles argues the indictment is insufficient because it fails to allege his faculties were “materially and appreciably impaired” by the use of alcohol or drugs, as required by the statute. We disagree.

A circuit court lacks subject matter jurisdiction where an indictment is insufficient to charge an offense. Hooks v. State, 353 S.C. 48, 577 S.E.2d 211 (2003). An indictment is sufficient if it contains the necessary elements of the offense to be charged and apprises the defendant what he must be prepared to meet. Id. Whether an indictment could be more definite or certain is irrelevant. Id.

Knuckles’ indictment alleges:

That Harold D. Knuckles, Sr. did in Cherokee County on or about July 17, 1998, drive a vehicle under the influence of intoxicating liquors, and/or narcotic drugs, barbiturates, paraldehydes[,] drugs and herbs; such not being the first offense within a period of ten years including and immediately preceding the foregoing date.

Section 56-5-2930 prohibits the operation of a motor vehicle while under the:

(1) influence of alcohol to the extent that the person’s faculties to drive are materially and appreciably impaired;

(2) influence of any other drug or a combination of other drugs or substances which cause impairment to the extent that the person’s faculties to drive are materially and appreciably impaired; or

(3) combined influence of alcohol and any other drug or drugs, or substances which cause impairment to the extent that the person’s faculties to drive are materially and appreciably impaired.

S.C.Code Ann. § 56-5-2930 (Supp.1998).

The corpus delicti of DUI is defined as (1) driving a vehicle; (2) within this state; (3) while under the influence of intoxicating liquors or drugs. Knuckles, 348 S.C. at 600, 560 S.E.2d at 430 (Shuler dissenting); see State v. Osborne, 335 S.C. 172, 516 S.E.2d 201 (1999); State v. Salisbury, 343 S.C. 520, 524, 541 S.E.2d 247, 248-49 (2001); State v. McCombs, 335 S.C. 123, 515 S.E.2d 547 (Ct.App.1999); Kerr, supra; but see State v. Russell, 345 S.C. 128, 134, 546 S.E.2d 202, 205 (Ct.App.2001).

The term “materially and appreciably impaired” as it relates to DUI may be traced to State v. Kerr, 330 S.C. 132, 498 S.E.2d 212 (Ct.App.1998). In Kerr the court addressed the level of proof required of the State to prove the defendant was “under the influence of alcohol.” Id. at 144, 498 S.E.2d at 218.

Subsequently, the Legislature amended § 56-5-2930 to include the “materially and appreciably impaired” language. The statutory inclusion of the level or standard of proof required does not change the corpus delicti of this crime.

The indictment in this case is sufficient to confer jurisdiction on the circuit court.

We REVERSE.

TOAL, C.J., MOORE, WALLER and PLEICONES, JJ., concur.