State v. Watkins

We granted certiorari to review a Court of Appeals decision that reversed respondent’s convictions for armed robbery and possession of a weapon during a violent crime. State v. Watkins, Op. No. 2011-UP-091 (S.C. Ct.App. filed March 8, 2011). The Court of Appeals purported to adopt a rule1 requiring that a trial “judge must grant a recusal motion made during a new trial arising from a [post-conviction relief] hearing in which the judge also sat.” Id. We reverse the holding that creates this rule, find no error in the trial judge’s denial of respondent’s recusal request, determine there is no…