Court of Appeals of South Carolina

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State v. Franklin — Voice ID Sufficient to Authenticate Out-of-State Jail Calls; Ankle Monitor Speed Data Admission Harmless

The South Carolina Court of Appeals affirmed murder and weapons convictions, holding that out-of-state jail calls were properly authenticated by voice identification under Rule 901(b)(5), SCRE, without requiring a records custodian from the Ohio jail, and that admission of ankle monitor speed data was harmless because the same inference was established by multiple independent evidence sources.

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State v. Joyner — Self-Defense Instruction Properly Denied; Home Detention Credit Discretionary Under S.C. Code § 24-13-40

The South Carolina Court of Appeals affirmed voluntary manslaughter and weapons convictions, holding that the trial court properly refused a self-defense instruction because no evidence showed Joyner was in imminent danger when she fired from the backseat of a departing vehicle, and that the denial of sentence credit for three years on monitored home detention was a proper exercise of the court’s discretion under the “may” language of S.C. Code Ann. § 24-13-40.

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State v. Beebe — Prior-Abuse Evidence Admissible as Rehabilitation of Eyewitness; Unpreserved Objections Waived

The South Carolina Court of Appeals affirmed a murder conviction, holding that evidence of the defendant’s domestic abuse against his wife was admissible as rehabilitation evidence under Rules 607 and 608, SCRE, to explain why she initially gave inconsistent statements to police, and that the defendant’s remaining arguments were unpreserved because he failed to object contemporaneously when Dani’s trial testimony arguably exceeded the trial court’s pretrial ruling.

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State v. Barry W. Jones — Armed Return After “Kill” Text Defeats Stand Your Ground Immunity; Suicide Attempt Evidence Properly Admitted

The South Carolina Court of Appeals affirmed a murder conviction, holding that the defendant’s decision to return to the confrontation site while armed — minutes after texting “I’m gonna kill that BBoy” — defeated Stand Your Ground immunity under the Protection of Persons and Property Act; suicide attempt evidence was properly admitted under the Cartwright framework; and the self-defense jury charge adequately covered the law.

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