The South Carolina Court of Appeals reversed a lower court’s denial of a defendant’s post-conviction relief action, finding his trial counsel was ineffective for failing to object to the solicitor’s references to his “patterns of behavior” during closing arguments.
The petitioner, Mack Washington Jr., appealed the denial of his PCR application due to his prior counsel’s failure to preserve the issue of the solicitor’s references to “a pattern” of criminal conduct, which was neither in the record nor testified to by the defendant.
