Littlefield v. Williams

2000

Venue: SC SC

Facts: Williams swindles a bunch of people, including Littlefield and Jeter. But the prosecutor dropped all charges involving Williams (who apparently had real losses, but somehow evidence must have been lacking).

Posture: The prosecutor gives notice that the charges at issue will be dismissed, and Williams is convicted in absentia. Williams files a motion to set aside the guilty plea because he and Jeter weren't notified of the hearing and couldn't attend. Trial court denies the motion finding that it lacks subject matter jurisdiction. Williams seeks a writ of mandamus.

Issue: Does an alleged victim have any rights under the relevant SC statutes when the perpetrator is arrested but not indicted for offenses involving the victim?

Holding: Not after the criminal proceedings have terminated.

Rule: A victim's rights terminate when criminal proceedings and post-conviction proceedings have terminated. Also, even if the solicitor fails to honor the vitim's rights during the proceeding, the court can't issue a writ of mandamus to re-open a criminal proceeding once it is resolved.

Reasoning: To have rights, you have to be a victim as defined by the statute. But rights change over the course of the proceeding. And they evaporate when it's done.

Dicta: