The South Carolina Supreme Court recently affirmed the murder conviction of Andre T. Heatley Jr., ruling that his trial counsel was not ineffective for failing to request a specific jury instruction on circumstantial evidence. This decision, filed on July 22, 2026, affects Heatley, who was convicted of murder and armed robbery in 2016, and clarifies the standards for jury instructions in cases relying on circumstantial evidence.
The court's ruling is significant because it addresses ongoing confusion regarding jury instructions on circumstantial evidence in South Carolina. The court's decision may set a precedent for future cases, impacting how similar cases are prosecuted and defended in the state.
Background
Andre T. Heatley Jr. was convicted in 2016 for the murder of Deanndra Roach and armed robbery. The case was primarily based on circumstantial evidence, including text messages and cell phone data that linked Heatley to the crime. On the night of the murder, Roach was shot multiple times in her car, and Heatley was later seen attempting to use her credit card at ATMs.
After his conviction, Heatley appealed, arguing that his trial counsel was ineffective for not requesting a specific jury instruction known as the Logan charge, which relates to how juries should evaluate circumstantial evidence. The appeal was denied, leading Heatley to file a post-conviction relief (PCR) case. The PCR court ruled against him, prompting Heatley to seek further review from the South Carolina Supreme Court.
The Ruling
The South Carolina Supreme Court, in its opinion, upheld the PCR court's decision, stating that Heatley's trial counsel was not ineffective. The court noted, "We find Heatley's trial counsel was not deficient in not requesting a Logan charge." The ruling clarified that the trial court had provided a constitutionally sound reasonable doubt charge and had adequately explained the difference between direct and circumstantial evidence.
Justice Few, writing for the court, stated that the confusion surrounding the various circumstantial evidence charges in South Carolina law needed to be addressed. The court overruled part of the previous Logan decision to eliminate this confusion, emphasizing that the reasonable doubt standard is the only standard on which a jury should be instructed.
Impact
This ruling is expected to have a significant impact on future criminal cases in South Carolina, particularly those involving circumstantial evidence. By affirming the PCR court's decision and clarifying the standards for jury instructions, the court aims to reduce confusion among judges and attorneys regarding how to instruct juries in such cases.
Heatley's case may also influence other defendants who argue ineffective assistance of counsel based on similar grounds. The decision reinforces the idea that trial counsel's performance will not be deemed deficient if the jury is properly instructed on the reasonable doubt standard and the nature of circumstantial evidence.
What's Next
While the South Carolina Supreme Court has affirmed the ruling, Heatley may still seek other legal avenues, including a potential federal appeal. However, the court's decision sets a strong precedent for similar cases moving forward.