harmless error in South Carolina

2024The trial court gave an implied malice instruction; however, this instruction never indicated malice could be inferred from Ruttle's use of the handgun in the killing. insufficient to warrant [an appellate court's] reversal."); Smith, 430 S.C. at 233, 845 S.E.2d at 498 ("[E]rroneous jury instructions are subject to a harmless error analysis."); Burdette, 427 S.C. at 496, 832 S.E.2d at 578 ("When considering whether an error with respect to a jury instruction was harmless, we must 'determine beyond a reasonable doubt that the error complained of did not contribute to the verdict.'" (quoting Sta

2024The trial court gave an implied malice instruction; however, this instruction never indicated malice could be inferred from Ruttle's use of the handgun in the killing. insufficient to warrant [an appellate court's] reversal."); Smith, 430 S.C. at 233, 845 S.E.2d at 498 ("[E]rroneous jury instructions are subject to a harmless error analysis."); Burdette, 427 S.C. at 496, 832 S.E.2d at 578 ("When considering whether an error with respect to a jury instruction was harmless, we must 'determine beyond a reasonable doubt that the error complained of did not contribute to the verdict.'" (quoting Sta

2026See State v. Collins, 409 S.C. 524, 537 , 763 S.E.2d 22, 29 (2014) ("The harmless error rule generally provides that an error is harmless beyond a reasonable doubt if it did not contribute to the verdict obtained.").

2026See State v. Collins, 409 S.C. 524, 537 , 763 S.E.2d 22, 29 (2014) ("The harmless error rule generally provides that an error is harmless beyond a reasonable doubt if it did not contribute to the verdict obtained.").

2025Code Ann. §§ 44-48-10 to -170 (2018 & Supp. 2024). and the following authorities: Logan, 405 S.C. at 99 , 747 S.E.2d at 452 (holding that when the State relies on circumstantial evidence, the trial court should—if requested—charge the jury that "to the extent the State relies on circumstantial evidence, all of the circumstances must be consistent with each other, and when taken together, point conclusively to the guilt of the accused beyond a reasonable doubt"); State v. Herndon, 430 S.C. 367 , 373, 845 S.E.2d 499 , 502 (2020) (explaining the failure to give a requested Logan charge is subject

2025Code Ann. §§ 44-48-10 to -170 (2018 & Supp. 2024). and the following authorities: Logan, 405 S.C. at 99 , 747 S.E.2d at 452 (holding that when the State relies on circumstantial evidence, the trial court should—if requested—charge the jury that "to the extent the State relies on circumstantial evidence, all of the circumstances must be consistent with each other, and when taken together, point conclusively to the guilt of the accused beyond a reasonable doubt"); State v. Herndon, 430 S.C. 367 , 373, 845 S.E.2d 499 , 502 (2020) (explaining the failure to give a requested Logan charge is subject

2026"A harmless error analysis is contextual and specific to the circumstances of the case." Id. at 566 , 816 S.E.2d at 573 (quoting State v. Byers, 392 S.C. 438, 447-48 , 710 S.E.2d 55, 60 (2011)).

2026"A harmless error analysis is contextual and specific to the circumstances of the case." Id. at 566 , 816 S.E.2d at 573 (quoting State v. Byers, 392 S.C. 438, 447-48 , 710 S.E.2d 55, 60 (2011)).

2019"Engaging in this harmless error analysis, we note that our jurisprudence requires us not to question whether the State proved its case beyond a reasonable doubt, but whether beyond a reasonable doubt the trial error did not contribute to the guilty verdict." State v. Tapp, 398 S.C. 376 , 389–90, 728 S.E.2d 468, 475 (2012).

2019"Engaging in this harmless error analysis, we note that our jurisprudence requires us not to question whether the State proved its case beyond a reasonable doubt, but whether beyond a reasonable doubt the trial error did not contribute to the guilty verdict." State v. Tapp, 398 S.C. 376 , 389–90, 728 S.E.2d 468, 475 (2012).

2025Still, "[a] violation of the Confrontation Clause is not per se reversible but is subject to a harmless error analysis." State v. Gracely, 399 S.C. 363, 375 , 731 S.E.2d 880, 886 (2012).

2025Still, "[a] violation of the Confrontation Clause is not per se reversible but is subject to a harmless error analysis." State v. Gracely, 399 S.C. 363, 375 , 731 S.E.2d 880, 886 (2012).

2013See State v. Green, 397 S.C. 268, 287 , 724 S.E.2d 664, 673 (2012) ("Prejudice occurs when there is reasonable probability the wrongly admitted evidence influenced the jury's verdict."); State v. Byers, 392 S.C. 438, 447-48 , 710 S.E.2d 55, 60 (2011) (quoting State v. Reeves, 301 S.C. 191, 193-94 , 391 S.E.2d 241, 243 (1990) (alteration in original)) ("A harmless error analysis is contextual and specific to the circumstances of the case: 'No definite rule of law governs [a finding of harmless error]; rather the materiality and prejudicial character of the error must be determined from its rela

2013See State v. Green, 397 S.C. 268, 287 , 724 S.E.2d 664, 673 (2012) ("Prejudice occurs when there is reasonable probability the wrongly admitted evidence influenced the jury's verdict."); State v. Byers, 392 S.C. 438, 447-48 , 710 S.E.2d 55, 60 (2011) (quoting State v. Reeves, 301 S.C. 191, 193-94 , 391 S.E.2d 241, 243 (1990) (alteration in original)) ("A harmless error analysis is contextual and specific to the circumstances of the case: 'No definite rule of law governs [a finding of harmless error]; rather the materiality and prejudicial character of the error must be determined from its rela

2025However, the supreme court qualified that statement, explaining "despite the strong interests upon which the harmless-error doctrine is based, there are certain constitutional rights which are 'so basic to a fair trial that their infraction can never be treated as harmless error.'" Id. at 246-47 , 741 S.E.2d at 705 (quoting Arizona v. Fulminante, 499 U.S. 279, 308 (1991)).

2024Id. at 1305–06; cf. State v. Rezk, 840 A.2d 758 , 487–93 (N.H. 2004) (explaining false promises of confidentiality and leniency, unlike other types of promises, can be dispositive of the issue of voluntariness, but error in the admission of an involuntary statement is still subject to a harmless error analysis because it is a trial error, not a structural error (citing Arizona v. Fulminante, 499 U.S. 279 , 307–10 (1991))).

2026"In applying the harmless error rule, the court must be able to declare the error had little, if any, likelihood of having changed the result of the trial and the court must be able to declare such belief beyond a reasonable doubt." State v. Watts, 321 S.C. 158, 165 , 467 S.E.2d 272, 277 (Ct. App. 1996) In Simmons, our supreme court determined an error in allowing inadmissible hearsay testimony in a CSC with a minor case was subject to a harmless error analysis. 423 S.C. at 565 , 816 S.E.2d at 573 .

2026"In applying the harmless error rule, the court must be able to declare the error had little, if any, likelihood of having changed the result of the trial and the court must be able to declare such belief beyond a reasonable doubt." State v. Watts, 321 S.C. 158, 165 , 467 S.E.2d 272, 277 (Ct. App. 1996) In Simmons, our supreme court determined an error in allowing inadmissible hearsay testimony in a CSC with a minor case was subject to a harmless error analysis. 423 S.C. at 565 , 816 S.E.2d at 573 .

2023However, a class of errors known as structural defects are not analyzed under the harmless error framework and are sometimes presumed prejudicial. 9 "[D]espite the strong interests upon which the harmless-error doctrine is based, there are certain constitutional rights which are so basic to a fair trial that their infraction can never be treated as harmless error." State v. Rivera, 402 S.C. 225 , 247–48, 741 S.E.2d 694, 705 (2013) (citing Chapman, 386 U.S. at 23 ).

2016“Harmless error rules, even in dealing with constitutional errors, ’serve a very useful purpose insofar as they block setting aside convictions for small errors or defects that have little, if any, likelihood of having changed the result of the trial.’” White, 410 S.C. at 59 , 762 S.E.2d at 728 (quoting Chapman v. California, 386 U.S. 18, 22 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967)).

2025He asserts that in doing so, the PCR court applied a harmless-error analysis to the denial of Petitioner's right to testify on his own behalf, contrary to State v. Rivera, 402 S.C. 225 , 741 S.E.2d 694 (2013).

2025The supreme court disagreed with the State's contention "that the denial of a defendant's right to testify does not in all cases render a criminal trial fundamentally unfair or call into question the reliability of the trial as a vehicle for determining guilt or innocence" and that "such an error is appropriately characterized as a 'trial error' which is subject to the harmless-error doctrine." Id.

2023See State v. Burdette, 427 S.C. 490 , 496, 832 S.E.2d 575 , 578 (2019) ("Errors, including erroneous jury instructions, are subject to harmless error analysis." (quoting State v. Belcher, 385 S.C. 597, 611 , 685 S.E.2d 802, 809 (2009), overruled on other grounds by Burdette, 427 S.C. at 503, 832 S.E.2d at 582-83)); State v. Middleton, 407 S.C. 312, 317 , 755 S.E.2d 432, 435 (2014) ("In making a harmless error analysis, [the appellate court's] inquiry is . . . whether the erroneous charge contributed to the verdict rendered."); State v. Logan, 405 S.C. 83, 90 , 747 S.E.2d 444, 448 (2013) ("In r

2023See State v. Burdette, 427 S.C. 490 , 496, 832 S.E.2d 575 , 578 (2019) ("Errors, including erroneous jury instructions, are subject to harmless error analysis." (quoting State v. Belcher, 385 S.C. 597, 611 , 685 S.E.2d 802, 809 (2009), overruled on other grounds by Burdette, 427 S.C. at 503, 832 S.E.2d at 582-83)); State v. Middleton, 407 S.C. 312, 317 , 755 S.E.2d 432, 435 (2014) ("In making a harmless error analysis, [the appellate court's] inquiry is . . . whether the erroneous charge contributed to the verdict rendered."); State v. Logan, 405 S.C. 83, 90 , 747 S.E.2d 444, 448 (2013) ("In r

2026See State v. Collins, 409 S.C. 524, 537 , 763 S.E.2d 22, 29 (2014) ("The harmless error rule generally provides that an error is harmless beyond a reasonable doubt if it did not contribute to the verdict obtained."); State v. Brown, 344 S.C. 70, 75 , 543 S.E.2d 552, 554-55 (2001) ("Whether an error in the admission of evidence is harmless generally depends upon its materiality in relation to the case as a whole."); State v. Mitchell, 286 S.C. 572, 573 , 336 S.E.2d 150, 151 (1985) ("Error is harmless when it 'could not reasonably have affected the result of the trial.'" (quoting State v. Key, 2

2026See State v. Collins, 409 S.C. 524, 537 , 763 S.E.2d 22, 29 (2014) ("The harmless error rule generally provides that an error is harmless beyond a reasonable doubt if it did not contribute to the verdict obtained."); State v. Brown, 344 S.C. 70, 75 , 543 S.E.2d 552, 554-55 (2001) ("Whether an error in the admission of evidence is harmless generally depends upon its materiality in relation to the case as a whole."); State v. Mitchell, 286 S.C. 572, 573 , 336 S.E.2d 150, 151 (1985) ("Error is harmless when it 'could not reasonably have affected the result of the trial.'" (quoting State v. Key, 2

2026"A harmless error analysis is contextual and specific to the circumstances of the case." Id. at 566 , 816 S.E.2d at 573 (quoting State v. Byers, 392 S.C. 438, 447-48 , 710 S.E.2d 55, 60 (2011)).

2021See State v. Brewer, 411 S.C. 401, 408 , 768 S.E.2d 656, 660 (2015) (stating the "[i]mproper admission of hearsay testimony constitutes reversible error only when the admission causes prejudice." (quoting State v. Jennings, 394 S.C. 473, 478 , 716 S.E.2d 91, 93 (2011))); State v. Gracely, 399 S.C. 363, 375 , 731 S.E.2d 880, 886 (2012) ("A violation of the Confrontation Clause is not per se reversible but is subject to a harmless error analysis.").

2012Confrontation Clause: State v. Holder, 382 S.C. 278, 285 , 676 S.E.2d 690, 694 (2009) ("Violations of the Confrontation Clause are subject to a harmless error analysis."); State v. Mizzell, 349 S.C. 326, 333 , 563 S.E.2d 315, 318-19 (2002) ("Whether an error is harmless depends on the particular facts of each case and upon a host of factors including: 'the importance of the witness' testimony in the prosecution's case, whether the testimony was cumulative, the presence or absence of evidence corroborating or contradicting the testimony of the witness on material points, the extent of cross-exa

2012Confrontation Clause: State v. Holder, 382 S.C. 278, 285 , 676 S.E.2d 690, 694 (2009) ("Violations of the Confrontation Clause are subject to a harmless error analysis."); State v. Mizzell, 349 S.C. 326, 333 , 563 S.E.2d 315, 318-19 (2002) ("Whether an error is harmless depends on the particular facts of each case and upon a host of factors including: 'the importance of the witness' testimony in the prosecution's case, whether the testimony was cumulative, the presence or absence of evidence corroborating or contradicting the testimony of the witness on material points, the extent of cross-exa

2020See In re Gonzalez, 409 S.C. 621, 636 , 763 S.E.2d 210, 217 (2014) ("No definite rule of law governs this finding [of harmless error]; rather, the materiality and prejudicial character of the error must be determined from its relationship to the entire case." (quoting Judy v. Judy, 384 S.C. 634, 646 , 682 S.E.2d 836, 842 (Ct. App. 2009))).

2020See In re Gonzalez, 409 S.C. 621, 636 , 763 S.E.2d 210, 217 (2014) ("No definite rule of law governs this finding [of harmless error]; rather, the materiality and prejudicial character of the error must be determined from its relationship to the entire case." (quoting Judy v. Judy, 384 S.C. 634, 646 , 682 S.E.2d 836, 842 (Ct. App. 2009))).

2020See Gracely, 399 S.C. at 375 , 731 S.E.2d at 886 ("A violation of the Confrontation Clause is not per se reversible but is subject to a harmless error analysis."); State v. Perez, 423 S.C. 491, 498 , 816 S.E.2d 550, 554 (2018) (stating whether a Confrontation Clause violation is harmless depends on "the importance of the witness'[s] testimony to the prosecution's case, whether the testimony was cumulative, the presence or absence of evidence corroborating or contradicting the testimony of the witness on material points, the extent of cross-examination otherwise permitted, and, of course, the o

2018See Young , 420 S.C. at 628, 803 S.E.2d at 899 ("The harmless-error doctrine recognizes the principle that the central purpose of a criminal trial is to decide the factual question of the defendant's guilt or innocence, and promotes public respect for the criminal process by focusing on the underlying fairness of the trial rather than on the virtually inevitable presence of immaterial error." (quoting Delaware v. Van Arsdall , 475 U.S. 673 , 681, 106 S.Ct. 1431 , 89 L.Ed.2d 674 (1986) ) ).

2024See State v. Collins, 409 S.C. 524, 537 , 763 S.E.2d 22, 29 (2014) ("The harmless error rule generally provides that an error is harmless beyond a reasonable doubt if it did not contribute to the verdict obtained."); State v. Brown, 344 S.C. 70, 75 , 543 S.E.2d 552, 554-55 (2001) ("Whether an error in the admission of evidence is harmless generally depends upon its materiality in relation to the case as a whole."); State v. Johnson, 298 S.C. 496, 499 , 381 S.E.2d 732, 733 (1989) ("The admission of improper evidence is harmless where it is merely cumulative to other evidence."); State v. Black,

2024See State v. Collins, 409 S.C. 524, 537 , 763 S.E.2d 22, 29 (2014) ("The harmless error rule generally provides that an error is harmless beyond a reasonable doubt if it did not contribute to the verdict obtained."); State v. Brown, 344 S.C. 70, 75 , 543 S.E.2d 552, 554-55 (2001) ("Whether an error in the admission of evidence is harmless generally depends upon its materiality in relation to the case as a whole."); State v. Johnson, 298 S.C. 496, 499 , 381 S.E.2d 732, 733 (1989) ("The admission of improper evidence is harmless where it is merely cumulative to other evidence."); State v. Black,

2022See State v. Collins, 409 S.C. 524, 538 , 763 S.E.2d 22 , 29– 30 (2014) (providing "error 'is harmless where a defendant's guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached'" (quoting State v. Bryant, 369 S.C. 511, 518 , 633 S.E.2d 152, 156 (2006))); State v. Heath, 433 S.C. 506 , 860 S.E.2d 673 , 679 (Ct. App. 2021) (providing in a CSC with a minor case, any error in admitting the victim's statements that defendant performed oral sex on her was harmless where there was overwhelming physical evidence of the defendant's guilt, includi

2022See State v. Collins, 409 S.C. 524, 538 , 763 S.E.2d 22 , 29– 30 (2014) (providing "error 'is harmless where a defendant's guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached'" (quoting State v. Bryant, 369 S.C. 511, 518 , 633 S.E.2d 152, 156 (2006))); State v. Heath, 433 S.C. 506 , 860 S.E.2d 673 , 679 (Ct. App. 2021) (providing in a CSC with a minor case, any error in admitting the victim's statements that defendant performed oral sex on her was harmless where there was overwhelming physical evidence of the defendant's guilt, includi

2014See Kromah, 401 S.C. at 361-62 , 737 S.E.2d at 501 (subjecting the erroneous qualification of a forensic interviewer to a harmless error analysis); see also State v. Jennings, 394 S.C. 473, 480 , 716 S.E.2d 91, 94-95 (2011) (subjecting improper vouching to a harmless error analysis).

2014See Kromah, 401 S.C. at 361-62 , 737 S.E.2d at 501 (subjecting the erroneous qualification of a forensic interviewer to a harmless error analysis); see also State v. Jennings, 394 S.C. 473, 480 , 716 S.E.2d 91, 94-95 (2011) (subjecting improper vouching to a harmless error analysis).

2022See State v. Collins, 409 S.C. 524, 538 , 763 S.E.2d 22 , 29– 30 (2014) (providing "error 'is harmless where a defendant's guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached'" (quoting State v. Bryant, 369 S.C. 511, 518 , 633 S.E.2d 152, 156 (2006))); State v. Heath, 433 S.C. 506 , 860 S.E.2d 673 , 679 (Ct. App. 2021) (providing in a CSC with a minor case, any error in admitting the victim's statements that defendant performed oral sex on her was harmless where there was overwhelming physical evidence of the defendant's guilt, includi

2022See State v. Collins, 409 S.C. 524, 538 , 763 S.E.2d 22 , 29– 30 (2014) (providing "error 'is harmless where a defendant's guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached'" (quoting State v. Bryant, 369 S.C. 511, 518 , 633 S.E.2d 152, 156 (2006))); State v. Heath, 433 S.C. 506 , 860 S.E.2d 673 , 679 (Ct. App. 2021) (providing in a CSC with a minor case, any error in admitting the victim's statements that defendant performed oral sex on her was harmless where there was overwhelming physical evidence of the defendant's guilt, includi

2010State v. Lee-Grigg, 374 S.C. 388, 411 , 649 S.E.2d 41, 53 (Ct.App.2007); see State v. Jefferies, 316 S.C. 13, 21 , 446 S.E.2d 427, 431 (1994) (noting that the harmless error analysis is appropriate where the error complained of is a "trial error" rather than a "structural defect" in the trial mechanism itself).

2010State v. Lee-Grigg, 374 S.C. 388, 411 , 649 S.E.2d 41, 53 (Ct.App.2007); see State v. Jefferies, 316 S.C. 13, 21 , 446 S.E.2d 427, 431 (1994) (noting that the harmless error analysis is appropriate where the error complained of is a "trial error" rather than a "structural defect" in the trial mechanism itself).

2026See State v. Collins, 409 S.C. 524, 537 , 763 S.E.2d 22, 29 (2014) ("The harmless error rule generally provides that an error is harmless beyond a reasonable doubt if it did not contribute to the verdict obtained."); State v. Brown, 344 S.C. 70, 75 , 543 S.E.2d 552, 554-55 (2001) ("Whether an error in the admission of evidence is harmless generally depends upon its materiality in relation to the case as a whole."); State v. Mitchell, 286 S.C. 572, 573 , 336 S.E.2d 150, 151 (1985) ("Error is harmless when it 'could not reasonably have affected the result of the trial.'" (quoting State v. Key, 2

2026See State v. Collins, 409 S.C. 524, 537 , 763 S.E.2d 22, 29 (2014) ("The harmless error rule generally provides that an error is harmless beyond a reasonable doubt if it did not contribute to the verdict obtained."); State v. Brown, 344 S.C. 70, 75 , 543 S.E.2d 552, 554-55 (2001) ("Whether an error in the admission of evidence is harmless generally depends upon its materiality in relation to the case as a whole."); State v. Mitchell, 286 S.C. 572, 573 , 336 S.E.2d 150, 151 (1985) ("Error is harmless when it 'could not reasonably have affected the result of the trial.'" (quoting State v. Key, 2

2025Code Ann. §§ 44-48-10 to -170 (2018 & Supp. 2024). and the following authorities: Logan, 405 S.C. at 99 , 747 S.E.2d at 452 (holding that when the State relies on circumstantial evidence, the trial court should—if requested—charge the jury that "to the extent the State relies on circumstantial evidence, all of the circumstances must be consistent with each other, and when taken together, point conclusively to the guilt of the accused beyond a reasonable doubt"); State v. Herndon, 430 S.C. 367 , 373, 845 S.E.2d 499 , 502 (2020) (explaining the failure to give a requested Logan charge is subject

2025Code Ann. §§ 44-48-10 to -170 (2018 & Supp. 2024). and the following authorities: Logan, 405 S.C. at 99 , 747 S.E.2d at 452 (holding that when the State relies on circumstantial evidence, the trial court should—if requested—charge the jury that "to the extent the State relies on circumstantial evidence, all of the circumstances must be consistent with each other, and when taken together, point conclusively to the guilt of the accused beyond a reasonable doubt"); State v. Herndon, 430 S.C. 367 , 373, 845 S.E.2d 499 , 502 (2020) (explaining the failure to give a requested Logan charge is subject

2001See Yates v. Evatt, 500 U.S. 391 , 111 S.Ct. 1884 , 114 L.Ed.2d 432 (1991) (jury charge on malice unconstitutionally shifted the burden of proof from the State to the defendant, nonetheless the constitutional violation was subject to harmless error analysis); Arizona v. Fulminante, 499 U.S. 279 , 111 *573 S.Ct. 1246, 113 L.Ed.2d 302 (1991) (admission of an involuntary confession subject to a harmless error analysis); Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967) (harmless error analysis used where state prosecutor’s argument and trial judge’s instruction continuousl

2001See Yates v. Evatt, 500 U.S. 391 , 111 S.Ct. 1884 , 114 L.Ed.2d 432 (1991) (jury charge on malice unconstitutionally shifted the burden of proof from the State to the defendant, nonetheless the constitutional violation was subject to harmless error analysis); Arizona v. Fulminante, 499 U.S. 279 , 111 *573 S.Ct. 1246, 113 L.Ed.2d 302 (1991) (admission of an involuntary confession subject to a harmless error analysis); Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967) (harmless error analysis used where state prosecutor’s argument and trial judge’s instruction continuousl

2026See State v. Collins, 409 S.C. 524, 537 , 763 S.E.2d 22, 29 (2014) ("The harmless error rule generally provides that an error is harmless beyond a reasonable doubt if it did not contribute to the verdict obtained."); State v. Brown, 344 S.C. 70, 75 , 543 S.E.2d 552, 554-55 (2001) ("Whether an error in the admission of evidence is harmless generally depends upon its materiality in relation to the case as a whole."); State v. Mitchell, 286 S.C. 572, 573 , 336 S.E.2d 150, 151 (1985) ("Error is harmless when it 'could not reasonably have affected the result of the trial.'" (quoting State v. Key, 2

2026See State v. Collins, 409 S.C. 524, 537 , 763 S.E.2d 22, 29 (2014) ("The harmless error rule generally provides that an error is harmless beyond a reasonable doubt if it did not contribute to the verdict obtained."); State v. Brown, 344 S.C. 70, 75 , 543 S.E.2d 552, 554-55 (2001) ("Whether an error in the admission of evidence is harmless generally depends upon its materiality in relation to the case as a whole."); State v. Mitchell, 286 S.C. 572, 573 , 336 S.E.2d 150, 151 (1985) ("Error is harmless when it 'could not reasonably have affected the result of the trial.'" (quoting State v. Key, 2

2017We affirm pursuant to Rule 220(b), SCACR, and the following authorities: State v. Haselden, 353 S.C. 190, 196 , 577 S.E.2d 445, 448 (2003) (providing the admission of improper evidence is subject to a harmless error analysis); State v. McLeod, 362 S.C. 73, 82 , 606 S.E.2d 215, 220 (Ct. App. 2004) ("Error is harmless whe[n] it could not reasonably have affected the result of the trial."); id. at 84–85, 606 S.E.2d at 221 (finding that even if the circuit court erred in admitting testimony, the error would be harmless given the overwhelming evidence against the defendant); State v. Holder, 382 S.

2012Confrontation Clause: State v. Holder, 382 S.C. 278, 285 , 676 S.E.2d 690, 694 (2009) ("Violations of the Confrontation Clause are subject to a harmless error analysis."); State v. Mizzell, 349 S.C. 326, 333 , 563 S.E.2d 315, 318-19 (2002) ("Whether an error is harmless depends on the particular facts of each case and upon a host of factors including: 'the importance of the witness' testimony in the prosecution's case, whether the testimony was cumulative, the presence or absence of evidence corroborating or contradicting the testimony of the witness on material points, the extent of cross-exa

2025He asserts that in doing so, the PCR court applied a harmless-error analysis to the denial of Petitioner's right to testify on his own behalf, contrary to State v. Rivera, 402 S.C. 225 , 741 S.E.2d 694 (2013).

2025However, a class of errors known as structural defects are not analyzed under the harmless error framework and are sometimes presumed prejudicial." Id. at 558, 895 S.E.2d at 685 (citation omitted). "[D]espite the strong interests upon which the harmless-error doctrine is based, there are certain constitutional rights which are so basic to a fair trial that their infraction can never be treated as harmless error." Id. (alteration in original) (quoting Rivera, 402 S.C. at 246-47 , 741 S.E.2d at 705 ).

2017We affirm pursuant to Rule 220(b), SCACR, and the following authorities: State v. Haselden, 353 S.C. 190, 196 , 577 S.E.2d 445, 448 (2003) (providing the admission of improper evidence is subject to a harmless error analysis); State v. McLeod, 362 S.C. 73, 82 , 606 S.E.2d 215, 220 (Ct. App. 2004) ("Error is harmless whe[n] it could not reasonably have affected the result of the trial."); id. at 84–85, 606 S.E.2d at 221 (finding that even if the circuit court erred in admitting testimony, the error would be harmless given the overwhelming evidence against the defendant); State v. Holder, 382 S.

2012Confrontation Clause: State v. Holder, 382 S.C. 278, 285 , 676 S.E.2d 690, 694 (2009) ("Violations of the Confrontation Clause are subject to a harmless error analysis."); State v. Mizzell, 349 S.C. 326, 333 , 563 S.E.2d 315, 318-19 (2002) ("Whether an error is harmless depends on the particular facts of each case and upon a host of factors including: 'the importance of the witness' testimony in the prosecution's case, whether the testimony was cumulative, the presence or absence of evidence corroborating or contradicting the testimony of the witness on material points, the extent of cross-exa