## Facts

- Phillip Lee Young decided, with two accomplices, to rob J.O. Cooke to obtain money for liquor and to kill Cooke during the robbery.
- Young went to Cooke’s front door and, by conversation, got Cooke to go to the kitchen to retrieve liquor.
- When Cooke returned from the kitchen with the liquor, Young stabbed Cooke.
- Young then instructed one of the accomplices to keep stabbing Cooke until Cooke died.
- The accomplice repeatedly stabbed Cooke, causing Cooke’s death.
- Young and the accomplices searched Cooke’s home for valuables and then left with the property they took.
- The State charged Young with first-degree murder, first-degree burglary, and other felonies tied to the break-in and robbery.
- A jury convicted Young of first-degree murder, first-degree burglary, and additional related offenses.
- The trial court imposed a death sentence for the murder, and Young appealed.

## Issues

1. In a capital prosecution, must the State plead (or be compelled to disclose by bill of particulars) the statutory aggravating circumstances it intends to submit at sentencing?
2. Did alleged trial and instruction errors require reversal of Young’s convictions or a new capital sentencing proceeding?
3. Was Young’s death sentence legally improper under the state’s mandatory appellate review of capital sentences (including proportionality review)?

## Decision

- The court affirmed Young’s convictions for first-degree murder, first-degree burglary, and the associated felonies.
- The court rejected Young’s claim that the murder indictment was defective for failing to allege the sentencing aggravating circumstances.
- The court concluded that the trial court did not commit reversible error by refusing to require pretrial specification of the sentencing aggravators through a bill of particulars.
- The court found no prejudicial error in the remaining claims aimed at the guilt-phase trial or the capital sentencing proceeding.
- After completing the required capital-sentence review, the court left the death sentence undisturbed.

## Legal Principles

- A first-degree murder indictment is sufficient if it properly charges the offense; statutory aggravating circumstances used only at capital sentencing are not required allegations in the indictment.
- A defendant is not automatically entitled to a bill of particulars that forces the State to identify, in advance of trial, which statutory aggravating circumstances it will seek to prove at capital sentencing; granting such a request is generally within the trial court’s discretion.
- Appellate review in capital cases includes review for legal error at both phases of trial and review of the death sentence under the jurisdiction’s statutory standards, including proportionality review where applicable.
- A death sentence may be upheld when the record supports the jury’s findings at sentencing and the reviewing court finds no basis to set aside the sentence under the governing review statute.

## Conclusion

State v. Young, 325 S.E.2d 181 (1985), arose from a planned robbery in which Young stabbed Cooke and directed an accomplice to continue stabbing until Cooke died; after Young’s convictions and death sentence, the court rejected challenges seeking greater pretrial notice of capital aggravating circumstances, found no reversible trial or sentencing error, and upheld the judgment following mandatory capital-sentence review.
