Background
On the morning of September 6, 2020, Redding’s girlfriend was found shot to death with a contact gunshot wound to the forehead in their shared motel room at the Forest Motel in Ridgeland. A shell casing was the only firearm evidence recovered; the gun itself was never found. No signs of a struggle were present. Redding was found sitting on the bed when officers arrived and appeared upset. Officers admitted they did not initially canvass other rooms or stop vehicles leaving the parking lot. Investigation revealed no witnesses heard a shot, saw Redding with a gun, or observed the couple arguing that morning. Redding immediately cooperated: he gave investigators his cell phones and a written statement, submitted to gunshot-residue (GSR) and DNA testing, and consented to multiple searches of the car he was driving.
Laboratory testing produced mixed results. Redding’s fingerprints were not on the shell casing—only Victim’s were. No GSR was found on Redding’s hands; two particles were found on the front of his shorts, but the expert conceded that residue is “extremely transferable” and could be picked up from sitting on a bed that had residue. A DNA mixture containing both Victim’s and Redding’s DNA was found on the blood on the interior motel door, and Redding’s YSTR profile appeared in the blood on the exterior door handle—consistent with Redding’s testimony that he touched Victim before leaving the room to find help. The State also presented evidence that Victim’s phone contained a video of Redding holding a “teal” gun, witnesses testified Redding had previously possessed a turquoise gun, Redding and Victim had a difficult relationship, and Redding changed his shirt between a 6:31 a.m. surveillance appearance at Parker’s Kitchen and his later return to the motel.
Redding presented a detailed alibi: his cell phone records, corroborated by a digital forensics expert, placed his phones on a route away from the motel from 6:15 through 7:35 a.m., and again from 8:27 a.m. to 9:32 a.m. Multiple witnesses—his cousin Danielle, his uncle Alvin Shiggs, and the motel owner Patel—each testified Redding appeared completely normal, with no blood visible, during those intervals. Redding explained the shirt change by pointing to a dust cover he repaired beneath the vehicle on a dirt driveway. The circuit court denied Redding’s directed verdict motions, a jury convicted him, and the court sentenced him to forty-eight years for murder and five years concurrently for the weapon charge.
The Court’s Holding
The Court of Appeals reversed, holding that the circuit court erred in submitting the murder charge to the jury. On directed verdict review, the court applies the “any evidence” standard, viewing all evidence in the light most favorable to the State and asking whether any direct or substantial circumstantial evidence reasonably tends to prove guilt. Circumstantial evidence “gains its strength from its combination with other evidence” and must be sufficient to allow a reasonable juror to find guilt beyond a reasonable doubt. But evidence that “raises a mere suspicion that the accused is guilty” must result in a directed verdict; suspicion is not proof.
Surveying the State’s circumstantial evidence—controlling behavior and a difficult relationship with Victim; access to a gun matching the murder caliber; being the last person to see Victim alive; changing shirts; and trace GSR on the shorts—the court found none of it, considered together, produced the requisite substantial evidence. Each piece had a plausible innocent explanation Redding placed before the jury and that was at least partially corroborated by independent witnesses. The court compared the case to a line of South Carolina directed-verdict reversals where fingerprint evidence, burn-pile items, victim’s belongings, or financial-motive evidence raised suspicion without establishing guilt: State v. Arnold, 361 S.C. 386 (2004); State v. Mitchell, 341 S.C. 406 (2000); State v. Bostick, 392 S.C. 134 (2011); and State v. Lollis, 343 S.C. 580 (2001). The court concluded the State’s evidence “rise[s] only to a mere suspicion of guilt” and reversed the conviction.
Key Takeaways
- Circumstantial evidence comprising a difficult domestic relationship, theoretical access to the murder weapon, last-known-contact with the victim, a clothing change, and trace GSR on clothing does not constitute “substantial circumstantial evidence” sufficient to survive a directed verdict motion when the defendant presents plausible, corroborated innocent explanations for each item.
- A directed verdict of acquittal is required when the State’s evidence raises only a suspicion of guilt, even if a jury might speculate that the defendant is guilty; the “any evidence” standard is not met by a collection of individually ambiguous circumstantial facts that yield no reasonable inference of guilt beyond reasonable doubt when viewed in combination.
- Fingerprint absence on a shell casing, absence of GSR on hands (with expert concession of transferability), and DNA on a door consistent with the defendant’s own explanation of touching the victim do not supply the additional quantum of proof needed to push from suspicion to substantial evidence.
- A strong alibi corroborated by objective cell-phone-tower data and multiple witnesses who observed nothing unusual is a significant factor in the directed-verdict calculus—particularly when the State cannot establish the victim’s time of death within the alibi window.
Why It Matters
Domestic-violence homicide prosecutions often depend heavily on opportunity and relationship evidence in the absence of direct proof. Redding is a reminder that the directed-verdict standard, while deferential to the State on appeal, has real teeth when the defendant presents a corroborated alibi and the physical evidence supports alternative explanations. Prosecutors should evaluate whether they can establish a specific window of opportunity consistent with the evidence before relying on circumstantial motive-and-access proof alone.
Defense practitioners in South Carolina courts should note the court’s careful survey of the directed-verdict case law: Arnold, Mitchell, Bostick, and Lollis each illustrate the point that a collection of individually suggestive facts does not become substantial when no individual fact amounts to proof and the defendant has offered plausible countervailing evidence. If your client has a corroborated alibi and the physical evidence is ambiguous, a directed verdict motion made and renewed at the close of the State’s case is not just a formality—it can be a winning argument on appeal.