International Filter Co. v. Conroe Gin

Case Name: State v. Worley, 265 S.C. 551, 220 S.E.2d 242 (1975)

Facts: James Worley, the Defendant in this case, was an inmate at Richland County Prison camp in 1972. While in the camp, he contracted a severe case of poison ivy. He asked three times to see a doctor, but was not allowed to do so. He was given calamine lotion as treatment. The Defendant voluntarily left the Camp and went to Georgia, where he was treated by a doctor. He was arrested two years later in Florida and charged with the crime of escape from lawful confinement.

Procedural History: The Defendant was convicted in South Carolina state court of escape and argued at trial that his escape was justified because of inadequate medical treatment at the prison camp. The trial judge refused to allow the Defendant to present the affirmative defense of necessity to the jury. The Defendant appeals his conviction on the basis that the trial judge should have charged the jury with the necessity defense.

Issue: Did the trial court err in failing to allow the jury to consider a necessity defense in an escape from lawful confinement case where the Defendant left a prison camp due to inadequate medical treatment and promptly sought proper medical treatment, but failed to report to authorities during the two years that followed?

Holding : No, the trial court did not err in withdrawing the necessity defense from the jury’s consideration because the Defendant remained at large, without reporting to authorities, for two years after he left the prison camp. (Affirmed.)

Pre-Existing Rules: The case does not cite the statute that criminalizes escape from lawful confinement, but presumably such a statute exists. The necessity defense had apparently not been recognized by South Carolina courts in this context, so the criteria set forth in this case define a new affirmative defense.

Reasoning: The court reasoned that the defense of necessity must be available only in limited situations because legal channels exist to address problems with medical treatment, and, therefore, prisoners should not be the ones to decide when escape is justified. The court observed that escapes are “dangerous to prison guards, officials and the public and are disruptive of prison routine.”

Judgment: The court set forth six criteria that must be satisfied in order for the necessity defense to be available to a prisoner charged with escape: 1) the prisoner must have informed prison officials of the problem and been denied medical treatment; 2) there must not be time for a court to address the problem; 3) the escape must not involve force or threat of force; 4) the escapee must promptly seek medical care; 5) the treating doctor must agree that the prisoner was in danger of death or “immediate serious permanent” bodily harm absent prompt medical care; and 6) the prisoner must report to authorities immediately after receiving medical care. Because the 6^th criterion was not satisfied by the defendant, the court held that the trial court did not err in withholding the necessity  defense.