BEAUFORT, SC (August 23, 2018) – A South Carolina appeals court has upheld the murder conviction of a Hilton Head Island man in the 2012 shooting death of 8-year-old Khalil Singleton, who was caught in the crossfire of a gun battle as he played in his grandmother’s yard.
Aaron Young Jr, one of three men successfully prosecuted by 14th Circuit Solicitor Duffie Stone for the murder, sought to overturn his 2014 guilty verdict because another man, Tyrone Robinson, fired the fatal shot. However, the S.C. Court of Appeals unanimously upheld the conviction and validated Stone’s unique strategy in a decision issued Aug. 22, 2018.
To convict both Aaron Young Sr. and Aaron Young Jr., Stone invoked a centuries-old legal concept, “mutual combat,” which holds each participant in a shootout responsible for each bullet fired. Aaron Young Jr. argued the prosecution’s strategy has not been commonly used and should not be the law in South Carolina.
“This argument has been rarely used in murder cases, so I expected the defense to appeal,” Stone said. “However, I believed then, as I do now, that this is and should be the law. The Court of Appeals agreed.
“The legal theory of mutual combat allowed us to successfully prosecute everyone involved in the death of Khalil Singleton, not just the triggerman.”
All three combatants were armed and fired at each other at various locations on Hilton Head Island during a running gun battle. The conflict started when Robinson drove to the Youngs’ home and fired a .38-caliber handgun during a struggle with Young Sr.
Robinson returned to his vehicle and sped away. The Youngs went into their house and retrieved a semi-automatic pistol and ammunition, then got into their pickup truck and began searching for Robinson. They caught up with him near his home. When gunfire erupted, neighbors called their children indoors, but Singleton, staying with his grandmother that day, was struck before he made it inside.
Robinson and the Youngs were convicted of Singleton’s murder in separate trials in 2014 and 2015 – the end of a three-year process that involved more than 150 pieces of evidence and hundreds of man hours.
In preparing his case, Stone revived a doctrine rooted in English common law, believed to have been last used in a similar South Carolina case in 1915, following a labor dispute at a Greenville textile mill. The doctrine holds that when participants enter a fight in which they know deadly weapons will be used, everyone engaged is equally responsible for any death that ensues. The doctrine applies regardless of the side on which the combatant fought and regardless of whether the combatant used a deadly weapon himself.
In his appeal, Young Jr. asserted that the law of mutual combat is only a limitation on a self-defense argument and that the law would not apply because Singleton was not a combatant. The court rejected both arguments.
“Although we acknowledge the doctrine of mutual combat has ‘fallen out of common use in recent years,’ we find South Carolina law still recognizes mutual combat as a basis for a murder charge,” the court said in its ruling.
The court’s decision could still be appealed to the S.C. Supreme Court.
