Bruno v. State

Chief Justice TOAL:

I respectfully dissent. In my opinion, counsel’s failure to object to Ross’ references to taking a polygraph test was deficient and prejudicial to Bruno. I would find trial counsel’s failure to object to Ross’ statement that he had taken a polygraph, coupled with the State’s closing argument that all of Ross’ statements were “corroborated,” impermissibly bolstered Ross’ testimony, resulting in prejudice to Bruno. Such prejudice requires reversal of the denial of Bruno’s application for PCR.

As noted by the majority, Strickland v. Washington requires a PCR applicant to show (1) counsel’s representation fell below an objective standard of reasonableness and, (2) but for counsel’s errors, there is a reasonable • probability the result at trial would have been different. The majority finds defense counsel deficient for failing to object to the polygraph evidence, thereby violating the first prong of Strickland. I agree with the majority’s analysis up to this point, but disagree with the majority’s conclusion that Bruno was not prejudiced by counsel’s error.

The majority finds trial counsel deficient based on our precedent that even a passing reference to a polygraph can create an impermissible inference. See State v. Pressley, 290 S.C. 251, 349 S.E.2d 403 (1986)(citing State v. McGuire, 272 S.C. 547, 253 S.E.2d 103 (1979)). Our case law indicates defense counsel should object to the even the slightest reference to a polygraph and should also request a curative instruction from the judge. See Id. In this case, trial counsel did not object or request a curative instruction when the State’s chief •witness, Ross, referred to taking a polygraph in his testimony. Furthermore, counsel likewise failed to object to State’s clos*454ing statement that their chief witness’ story had been corroborated: Ross “told the officers what happened at Starvin’ Marvin and at the bridge. He didn’t lie about it because everything’s been corroborated.” Ross’ story about the recovery of the weapon at the bridge was corroborated when the police found the weapon there, but Ross’ version of the events at the Starvin’ Marvin was not likewise corroborated. Bruno certainly told a different version and no other witness testified to corroborate Ross’ story. Therefore, the only possible inference the jury could draw from this closing statement was that Ross’ polygraph results corroborated his testimony.

Therefore, I would find Ross’ testimony was improperly bolstered by his reference to his polygraph test and by the reference to corroboration of Ross’ testimony in the closing statement. Although Ross did not testify about the results of his polygraph, the State’s closing statement implies the results of the test corroborated Ross’ story. This Court has held repeatedly that polygraphs are inadmissible because they are unreliable. State v. Council, 335 S.C. 1, 515 S.E.2d 508 (1999). Whether the jury believed Bruno’s or Ross’ version of events, whether they believed Bruno or Ross to be more credible, determined the outcome of this case. Thus the testimony of Ross, as an eye-witness, was critical, and Ross’ reference to his polygraph test, coupled with the State’s closing that Ross’ testimony had been corroborated, gave Ross an unfair edge over Bruno. Therefore, I would hold Bruno was prejudiced by counsel’s failure to object to the impermissible polygraph evidence.

For the foregoing reasons, I would hold the trial counsel’s failure to object to the testimony that Ross had taken a polygraph test and the State’s closing argument that Ross’ testimony was corroborated, violated both prongs of Strickland v. Washington. Accordingly, I would REVERSE the PCR’s court’s ruling and REMAND for a new trial.

PLEICONES, J., concurs.