State v. William L. Roseboro, Jr.

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.

William Lee Roseboro, Jr., Appellant.

Appellate Case No. 2022-001551

Appeal From Sumter County
Alison Renee Lee, Circuit Court Judge

Unpublished Opinion No. 2025-UP-331
Submitted September 1, 2025 – Filed October 1, 2025

AFFIRMED

Appellate Defender Jessica M. Saxon, of Columbia, for
Appellant.

Attorney General Alan McCrory Wilson and Assistant
Attorney General Ambree Michele Muller, both of
Columbia; and Solicitor Ernest Adolphus Finney, III, of
Sumter, all for Respondent.

PER CURIAM: William Lee Roseboro, Jr., appeals his conviction for possession
with the intent to distribute marijuana and sentence of eight years' imprisonment.
On appeal, Roseboro argues the trial court erred by admitting drug evidence
because the State failed to establish a sufficient chain of custody; specifically,
Roseboro contends the chain of custody was insufficient without testimony from
an employee at Roseboro's apartment complex. We affirm pursuant to Rule
220(b), SCACR.

We hold the trial court did not abuse its discretion by admitting the drug evidence
because the State established a sufficient chain of custody. Although Roseboro
contends the chain of custody was insufficient without the testimony of an
apartment complex employee, there was no testimony or evidence providing an
employee received the drug evidence during the controlled delivery to Roseboro.
See State v. Wright, 391 S.C. 436, 442, 706 S.E.2d 324, 326 (2011) ("The
admission of evidence is within the discretion of the trial court and will not be
reversed absent an abuse of discretion." (quoting State v. Gaster, 349 S.C. 545,
557, 564 S.E.2d 87, 93 (2002))); State v. Hatcher, 392 S.C. 86, 94, 708 S.E.2d 750,
754 (2011) ("Courts have abandoned inflexible rules regarding the chain of
custody and the admissibility of evidence in favor of a rule granting discretion to
the trial courts."); id. at 95, 708 S.E.2d at 755 ("Evidence is still required as to how
the item was obtained and how it was handled to ensure that it is, in fact, what it is
purported to be."); id. (explaining, however, that "[t]he State need not establish the
identity of every person handling fungible items in all circumstances; rather, the
standard is whether, in the discretion of the trial judge, the State has established the
chain of custody as far as practicable"); State v. Taylor, 360 S.C. 18, 25, 598
S.E.2d 735, 738 (Ct. App. 2004) ("[I]f the identity of each person in the chain
handling the evidence is established, and the manner of handling is reasonably
demonstrated, no abuse of discretion is shown in the admission [of the evidence],
absent proof of tampering, bad faith, or ill-motive."); S.C. Dep't of Soc. Servs. v.
Cochran, 364 S.C. 621, 629 n.1, 614 S.E.2d 642, 646 n.1 (2005) ("Whether the
chain of custody has been established as far as practicable . . . depends on the
unique factual circumstances of each case.").

AFFIRMED. 1

KONDUROS, GEATHERS, and VINSON, JJ., concur.

1
We decide this case without oral argument pursuant to Rule 215, SCACR.