State v. Troy C. Stevenson, Jr.
CourtCourt of Appeals of South Carolina
Date FiledNovember 12, 2026
Docket2026-UP-476
StatusUnpublished
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Full Opinion
THIS OPINION HAS NO PRECEDENTIAL VALUE. IT SHOULD NOT BE
CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING
EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.
THE STATE OF SOUTH CAROLINA
In The Court of Appeals
The State, Respondent,
v.
Troy Christopher Stevenson, Jr., Appellant.
Appellate Case No. 2024-000890
Appeal From Richland County
Daniel Coble, Circuit Court Judge
Unpublished Opinion No. 2026-UP-476
Submitted October 22, 2026 – Filed November 12, 2026
AFFIRMED
Clarence Rauch Wise, of Greenwood, for Appellant.
Attorney General Alan McCrory Wilson, Senior
Assistant Deputy Attorney General Melody Jane Brown,
and Solicitor Byron E. Gipson, all of Columbia, for
Respondent.
PER CURIAM: Troy Christopher Stevenson, Jr. appeals his conviction for
murder and sentence of life imprisonment. On appeal, Stevenson argues the trial
court erred in (1) failing to exclude evidence concerning a defective brake light
based on the State's late disclosure; (2) denying his motion for a directed verdict;
and (3) charging the jury on accomplice liability. We affirm pursuant to Rule
220(b), SCACR.
1. We hold the trial court did not abuse its discretion in declining to exclude
evidence of the defective brake light because the court required the defense to
inspect the vehicle before the State introduced the challenged evidence and
Stevenson failed to demonstrate resulting prejudice. See Rule 5(c), SCRCrimP
(providing that if a party discovers additional evidence or material previously
requested and subject to discovery, the party must "promptly notify the other
party . . . or the court of the existence of the additional evidence"); Rule 5(d)(2),
SCRCrimP (providing that when a party fails to comply with Rule 5, the trial court
may "permit the discovery or inspection, grant a continuance, or prohibit the party
from introducing evidence not disclosed, or it may enter such other order as it
deems just under the circumstances" and the court may "specify the time, place and
manner of making the discovery and inspection and may prescribe such terms and
conditions as are just"); State v. Kerr, 330 S.C. 132, 150, 498 S.E.2d 212, 221 (Ct.
App. 1998) ("Sanctions for noncompliance with disclosure rules are within the
discretion of the trial [court] and will not be disturbed absent an abuse of
discretion."); State v. Kennerly, 331 S.C. 442, 453-54, 503 S.E.2d 214, 220 (Ct.
App. 1998) ("Once a Rule 5 violation is shown, reversal is required only where the
defendant suffered prejudice from the violation."), aff'd, 337 S.C. 617, 524 S.E.2d
837 (1999).
2. We hold the trial court properly denied Stevenson's directed verdict motion
because, viewed in the light most favorable to the State, substantial circumstantial
evidence reasonably tended to prove his guilt. See State v. Elders, 386 S.C. 474,
480, 688 S.E.2d 857, 860 (Ct. App. 2010) ("When reviewing the denial of a motion
for a directed verdict, an appellate court must employ the same standard as the trial
court by viewing the evidence and all reasonable inferences in the light most
favorable to the nonmoving party."); id. ("This court will reverse a trial court's
ruling on a directed verdict motion if no evidence supports the trial court's decision
or the ruling is controlled by an error of law."); State v. Zeigler, 364 S.C. 94, 101,
610 S.E.2d 859, 863 (Ct. App. 2005) ("When ruling on a motion for a directed
verdict, the trial court is concerned with the existence or nonexistence of evidence,
not its weight."); id. at 101, 610 S.E.2d at 863 ("If there is any direct evidence or
any substantial circumstantial evidence reasonably tending to prove the guilt of the
accused, an appellate court must find the case was properly submitted to the
jury."). The State presented evidence that Stevenson communicated with
individuals connected to an earlier shooting at his mother's residence, received the
victim's address shortly before the murder, and traveled into the area of the victim's
address around the time of the murder, as reflected by the cell-site evidence. The
State also presented surveillance footage of a black sedan passing the victim's
address at the time ShotSpotter detected the gunfire, testimony that what appeared
to be a muzzle flash was visible on the surveillance footage as the sedan passed,
and evidence Stevenson regularly drove a black Honda similar to the sedan
depicted in the footage.
3. We hold the trial court did not abuse its discretion in charging accomplice
liability. See State v. Simmons, 384 S.C. 145, 178, 682 S.E.2d 19, 36 (Ct. App.
2009) ("In reviewing jury charges for error, this [c]ourt must consider the [trial]
court's jury charge as a whole in light of the evidence and issues presented at
trial."); State v. Mattison, 388 S.C. 469, 479, 697 S.E.2d 578, 584 (2010) ("An
appellate court will not reverse the trial [court]'s decision regarding a jury charge
absent an abuse of discretion."); State v. Brown, 362 S.C. 258, 262, 607 S.E.2d 93,
95 (Ct. App. 2004) ("If there is any evidence to support a jury charge, the trial
[court] should grant the request."); State v. Campbell, 443 S.C. 182, 194, 904
S.E.2d 441, 447 (2024) ("[A]ccomplice liability can be proven by circumstantial
evidence . . . ."); id. at 193, 904 S.E.2d at 446-47 (stating an accomplice liability
charge is appropriate when a defendant "personally commit[s] the crime or [is]
present at the scene of the crime and intentionally, or through a common design,
aid[s], abet[s], or assist[s] in the commission of that crime through some overt act"
(quoting State v. Condrey, 349 S.C. 184, 194, 562 S.E.2d 320, 325 (Ct. App.
2002))); State v. Johnson, 444 S.C. 442, 449-50, 908 S.E.2d 102, 107 (2024)
(holding a trial court "should charge the law of accomplice liability" in a gunshot
murder case when there is any evidence the defendant "had a mutual plan or
agreement with another person to commit the murder" and the other person fired
the fatal shot); id. at 449-51, 908 S.E.2d at 106-07 (finding an accomplice liability
charge was warranted when the record contained evidence the defendant had
planned the murder, arrived at the scene with an unidentified companion, and the
circumstances permitted a reasonable inference that if the companion was the
shooter, he acted in concert with the defendant). The evidence included testimony
that the surveillance footage appeared to show two occupants in the black sedan
that passed the victim's residence at the time of the shooting and that the shots
could have been fired through the passenger-side window by either the driver or a
passenger. The State also presented evidence linking Stevenson to a similar black
Honda and placing his phone in the area after he received the victim's address
shortly before the shooting. Thus, the evidence permitted a reasonable inference
that if Stevenson was driving and the passenger fired the shots, the two were acting
pursuant to a mutual plan.
AFFIRMED.1
THOMAS, KONDUROS, and CURTIS, JJ., concur.
1
We decide this case without oral argument pursuant to Rule 215, SCACR.