stating "an insubstantial error not affecting the result of the trial is harmless where 'guilt has been conclusively proven . . . such that no other rational conclusion can be reached.'" (quoting State v. Bailey, 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989))
How later courts described this case
- stating "an insubstantial error not affecting the result of the trial is harmless where 'guilt has been conclusively proven . . . such that no other rational conclusion can be reached.'" (quoting State v. Bailey, 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989))
- holding flight evidence was not relevant where the evidence did not create an inference that defendant’s alleged failure to stop for a blue light was motivated by his belief that the police were seeking him for his pending murder charge
- holding the admissibility of evidence is within the sound discretion of the trial court and will not be disturbed on appeal absent an abuse of discretion, and an abuse of discretion occurs when the trial court's admissibility determination either lacks evidentiary support or is controlled by an error of law
- holding the admissibility of evidence is within the trial court's discretion and will not be disturbed on appeal absent an abuse of discretion, and noting an abuse of discretion occurs when the trial court's ruling lacks evidentiary support or is controlled by an error of law
Written by the judges who cited it.
The opinion
Justice MOORE:
I respectfully dissent. I agree with the majority’s conclusion that the trial judge erred in allowing Lambert’s testimony; however, in my opinion, this error cannot be harmless. Identity was a critical issue in this case. Petitioner’s failure to stop for a blue light in 1999 was irrelevant to his identity as the murderer. The fact that the trial judge specifically instructed the jury it could consider this evidence for identification purposes made the erroneous admission of this evidence even more prejudicial. I would reverse and remand for a new trial.
PLEICONES, J., concurs.