Court Reverses Life Sentence Over Juror Excusal
South Carolina's appellate court overturned a life-without-parole assault conviction after finding a hearing-impaired juror was dismissed without an accommodation inquiry.
Updated on Nov. 10, 2026 in Criminal Justice
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The South Carolina Court of Appeals reversed Kendrick Montrez Lee's assault and battery of a high and aggravated nature conviction and his life-without-parole sentence under the state's Three Strikes law. The court found the trial court excused a prospective juror with a hearing impairment without individually questioning him about the extent of his impairment.
Why it matters
The ruling addresses whether a juror's disability can be treated as disqualifying without first determining if reasonable accommodations would allow service. It also bears on Batson challenges, after the trial court found no violation when the State struck the only Black prospective juror on the panel.
The Court of Appeals reversed Lee's conviction and life-without-parole sentence and remanded the case to the trial court. The juror's ability to serve with accommodations was never individually examined, and no retrial outcome has been reported.
The players
Court of Appeals of South Carolina
The state's intermediate appellate court, which reviews trial court decisions and reversed Lee's conviction and sentence in this case.
The details
Lee was convicted in Abbeville County of assault and battery after his cousin suffered life-threatening injuries and permanent brain damage. The State struck the only Black prospective juror, citing decades-old assault, disorderly conduct, and domestic violence convictions; after Lee raised a Batson challenge, the trial judge suggested seating the juror as an alternate, then abandoned that approach and found no violation.
Timeline
Jury selection occurred and the prospective juror was excused during Lee's trial in Abbeville County.
The Court of Appeals reversed the conviction and remanded the case on November 9, 2026.
Legal Context
Lee's life-without-parole sentence was imposed under South Carolina's Three Strikes law, which mandates life imprisonment for qualifying repeat offenders. This ruling addresses the procedural rights of defendants facing such sentences by focusing on how juror disqualification must be handled when a disability is involved.
The ruling means Lee will not serve the life-without-parole sentence while his case is remanded, and it sets a requirement that trial courts consider reasonable accommodations before excusing jurors with disabilities. Defense attorneys and prosecutors across South Carolina will need to apply that standard in future jury selections.
The takeaway
Jury selection in South Carolina now requires courts to examine whether accommodations can enable a juror with a disability to serve before excusing them. Attorneys on both sides should build that inquiry into their voir dire strategy.
Further reading
For related coverage of court procedures and sentencing, see Criminal Justice in South Carolina.
Source note: This article includes information reported by South Carolina Lawyers Weekly.
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