State v. Marcus Danta Batson

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.

Marcus Danta Batson, Appellant.

Appellate Case No. 2023-001593

Appeal From Spartanburg County
J. Derham Cole, Circuit Court Judge

Unpublished Opinion No. 2025-UP-341
Submitted September 1, 2025 – Filed October 8, 2025

AFFIRMED

Appellate Defender Joanna Katherine Delany, of
Columbia, for Appellant.

Attorney General Alan McCrory Wilson, Deputy
Attorney General Donald J. Zelenka, Senior Assistant
Deputy Attorney General Melody Jane Brown, and
Assistant Attorney General Richard Brandon Larrabee,
all of Columbia; and Solicitor Barry Joe Barnette, of
Spartanburg, all for Respondent.
PER CURIAM: Marcus Danta Batson appeals his convictions for two counts of
murder and sentence of life imprisonment without the possibility of parole. On
appeal, Batson argues the trial court erred in admitting his interrogation and
confession. We affirm pursuant to Rule 220(b), SCACR.

We hold the trial court did not err in admitting Batson's interrogation and
confession because based on the totality of the circumstances, his statement was
voluntary. See State v. Miller, 441 S.C. 106, 119, 893 S.E.2d 306, 313 (2023)
("[T]he question of voluntariness presents a mixed question of law and fact.");
State v. Moses, 390 S.C. 502, 513, 702 S.E.2d 395, 401 (Ct. App. 2010) ("[T]he
test for determining whether a defendant's confession was given freely, knowingly,
and voluntarily focuses upon whether the defendant's will was overborne by the
totality of the circumstances surrounding the confession."). Batson was advised of
his Miranda1 rights, waived those rights, and was not under duress. See State v.
Johnson, 422 S.C. 439, 455, 812 S.E.2d 739, 747 (Ct. App. 2018) ("Relevant
circumstances for the trial [court] to consider include . . . the failure to Mirandize,
the length of detention, the repeated and prolonged nature of the questioning, and
the use of physical punishment such as the deprivation of food or sleep.");
Berghuis v. Thompkins, 560 U.S. 370, 386-87 (2010) (finding an interrogation
conducted in a "standard-sized room in the middle of the afternoon" that lasted
three hours was not "inherently coercive" but acknowledging longer interrogations
were "improper" when accompanied by "other facts indicating coercion, such as an
incapacitated and sedated suspect, sleep and food deprivation, and threats"). The
officers conducting the interrogation did not coerce him or make any promises of
leniency. See State v. Rochester, 301 S.C. 196, 200, 391 S.E.2d 244, 246 (1990)
("[T]he confession may not be 'extracted by any sort of threats or violence, [or]
obtained by any direct or implied promises, however slight, [or] by the exertion of
improper influence.'" (alterations in the original) (quoting Hutto v. Ross, 429 U.S.
28, 30 (1976))); State v. Miller, 375 S.C. 370, 387, 652 S.E.2d 444, 453 (Ct. App.
2007) (finding a defendant's "statements were made in the 'hope' of leniency rather
than as a consequence of a 'promise'" when he was told "it was in his best interest
to cooperate" and where "no one made any direct or implied promises of
leniency").

AFFIRMED.2

WILLIAMS, C.J., and THOMAS and CURTIS, JJ., concur.

1
Miranda v. Arizona, 384 U.S. 436 (1966).
2
We decide this case without oral argument pursuant to Rule 215, SCACR.