State v. Reddick

I respectfully disagree with the majority as to the sufficiency of the indictment. The body of the indictment does not allege that Reddick is an inmate, nor does the indictment allege his status as an inmate in any similar language. Consequently, I would hold that the court did not have jurisdiction to try Reddick for this offense.

The caption of the indictment cannot be used to expand or contract the allegations, because it is not a part of the findings by the grand jury. State v. Lark, 64 S.C. 350, 353, 42 S.E. 175, 176-77 (1902); State v. Knuckles, 348 S.C. 593, 597-98, 560 S.E.2d 426,…