jury charge error in South Carolina

2026"When reviewing a jury charge for error, an appellate court considers the charge as a whole; the charge must be prejudicial to the appellant to warrant a new trial." State v. Stukes, 416 S.C. 493, 498 , 787 S.E.2d 480, 482 (2016).

2026"When reviewing a jury charge for error, an appellate court considers the charge as a whole; the charge must be prejudicial to the appellant to warrant a new trial." State v. Stukes, 416 S.C. 493, 498 , 787 S.E.2d 480, 482 (2016).

2022See State v. Long, 325 S.C. 59, 64 , 480 S.E.2d 62, 64 (1997) ("The law to be charged is determined from the evidence presented at trial."); State v. Cottrell, 421 S.C. 622, 643 , 809 S.E.2d 423, 435 (2017) (explaining this court will not reverse the trial court's decision regarding a jury charge unless there is an abuse of discretion); Douglas v. State, 332 S.C. 67, 73 , 504 S.E.2d 307, 310 (1998) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have

2022See State v. Long, 325 S.C. 59, 64 , 480 S.E.2d 62, 64 (1997) ("The law to be charged is determined from the evidence presented at trial."); State v. Cottrell, 421 S.C. 622, 643 , 809 S.E.2d 423, 435 (2017) (explaining this court will not reverse the trial court's decision regarding a jury charge unless there is an abuse of discretion); Douglas v. State, 332 S.C. 67, 73 , 504 S.E.2d 307, 310 (1998) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have

1992See State v. Tucker, 273 S.C. 736 , 259 S.E. (2d) 414 (1979) (the Supreme Court reviews a jury charge for error by considering the charge as a whole in light of the evidence and issues as presented during the trial).

1992See State v. Tucker, 273 S.C. 736 , 259 S.E. (2d) 414 (1979) (the Supreme Court reviews a jury charge for error by considering the charge as a whole in light of the evidence and issues as presented during the trial).

2026On appeal from the denial of a directed verdict, [the appellate court] views the evidence and all reasonable inferences in the light most favorable to the State." (alterations in original) (quoting State v. Butler, 407 S.C. 376, 381 , 755 S.E.2d 457, 460 (2014))); State v. Moultrie, 273 S.C. 532, 534 , 257 S.E.2d 730, 731 (1979) ("One element necessary to both self-defense and defense of habitation is that the defendant be without fault in bringing about the difficulty."); see also id. (holding when the defendant does not surrender after being given an opportunity to surrender and law enforcem

2026On appeal from the denial of a directed verdict, [the appellate court] views the evidence and all reasonable inferences in the light most favorable to the State." (alterations in original) (quoting State v. Butler, 407 S.C. 376, 381 , 755 S.E.2d 457, 460 (2014))); State v. Moultrie, 273 S.C. 532, 534 , 257 S.E.2d 730, 731 (1979) ("One element necessary to both self-defense and defense of habitation is that the defendant be without fault in bringing about the difficulty."); see also id. (holding when the defendant does not surrender after being given an opportunity to surrender and law enforcem

2026On appeal from the denial of a directed verdict, [the appellate court] views the evidence and all reasonable inferences in the light most favorable to the State." (alterations in original) (quoting State v. Butler, 407 S.C. 376, 381 , 755 S.E.2d 457, 460 (2014))); State v. Moultrie, 273 S.C. 532, 534 , 257 S.E.2d 730, 731 (1979) ("One element necessary to both self-defense and defense of habitation is that the defendant be without fault in bringing about the difficulty."); see also id. (holding when the defendant does not surrender after being given an opportunity to surrender and law enforcem

2026On appeal from the denial of a directed verdict, [the appellate court] views the evidence and all reasonable inferences in the light most favorable to the State." (alterations in original) (quoting State v. Butler, 407 S.C. 376, 381 , 755 S.E.2d 457, 460 (2014))); State v. Moultrie, 273 S.C. 532, 534 , 257 S.E.2d 730, 731 (1979) ("One element necessary to both self-defense and defense of habitation is that the defendant be without fault in bringing about the difficulty."); see also id. (holding when the defendant does not surrender after being given an opportunity to surrender and law enforcem

2022See State v. Long, 325 S.C. 59, 64 , 480 S.E.2d 62, 64 (1997) ("The law to be charged is determined from the evidence presented at trial."); State v. Cottrell, 421 S.C. 622, 643 , 809 S.E.2d 423, 435 (2017) (explaining this court will not reverse the trial court's decision regarding a jury charge unless there is an abuse of discretion); Douglas v. State, 332 S.C. 67, 73 , 504 S.E.2d 307, 310 (1998) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have

2022See State v. Long, 325 S.C. 59, 64 , 480 S.E.2d 62, 64 (1997) ("The law to be charged is determined from the evidence presented at trial."); State v. Cottrell, 421 S.C. 622, 643 , 809 S.E.2d 423, 435 (2017) (explaining this court will not reverse the trial court's decision regarding a jury charge unless there is an abuse of discretion); Douglas v. State, 332 S.C. 67, 73 , 504 S.E.2d 307, 310 (1998) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have

2022See State v. Long, 325 S.C. 59, 64 , 480 S.E.2d 62, 64 (1997) ("The law to be charged is determined from the evidence presented at trial."); State v. Cottrell, 421 S.C. 622, 643 , 809 S.E.2d 423, 435 (2017) (explaining this court will not reverse the trial court's decision regarding a jury charge unless there is an abuse of discretion); Douglas v. State, 332 S.C. 67, 73 , 504 S.E.2d 307, 310 (1998) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have

2022See State v. Long, 325 S.C. 59, 64 , 480 S.E.2d 62, 64 (1997) ("The law to be charged is determined from the evidence presented at trial."); State v. Cottrell, 421 S.C. 622, 643 , 809 S.E.2d 423, 435 (2017) (explaining this court will not reverse the trial court's decision regarding a jury charge unless there is an abuse of discretion); Douglas v. State, 332 S.C. 67, 73 , 504 S.E.2d 307, 310 (1998) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have

2022See State v. Long, 325 S.C. 59, 64 , 480 S.E.2d 62, 64 (1997) ("The law to be charged is determined from the evidence presented at trial."); State v. Cottrell, 421 S.C. 622, 643 , 809 S.E.2d 423, 435 (2017) (explaining this court will not reverse the trial court's decision regarding a jury charge unless there is an abuse of discretion); Douglas v. State, 332 S.C. 67, 73 , 504 S.E.2d 307, 310 (1998) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have

2022See State v. Long, 325 S.C. 59, 64 , 480 S.E.2d 62, 64 (1997) ("The law to be charged is determined from the evidence presented at trial."); State v. Cottrell, 421 S.C. 622, 643 , 809 S.E.2d 423, 435 (2017) (explaining this court will not reverse the trial court's decision regarding a jury charge unless there is an abuse of discretion); Douglas v. State, 332 S.C. 67, 73 , 504 S.E.2d 307, 310 (1998) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have

2022See State v. Long, 325 S.C. 59, 64 , 480 S.E.2d 62, 64 (1997) ("The law to be charged is determined from the evidence presented at trial."); State v. Cottrell, 421 S.C. 622, 643 , 809 S.E.2d 423, 435 (2017) (explaining this court will not reverse the trial court's decision regarding a jury charge unless there is an abuse of discretion); Douglas v. State, 332 S.C. 67, 73 , 504 S.E.2d 307, 310 (1998) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have

2022See State v. Long, 325 S.C. 59, 64 , 480 S.E.2d 62, 64 (1997) ("The law to be charged is determined from the evidence presented at trial."); State v. Cottrell, 421 S.C. 622, 643 , 809 S.E.2d 423, 435 (2017) (explaining this court will not reverse the trial court's decision regarding a jury charge unless there is an abuse of discretion); Douglas v. State, 332 S.C. 67, 73 , 504 S.E.2d 307, 310 (1998) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have

2021See State v. Rye, 375 S.C. 119, 124 , 651 S.E.2d 321, 323 (2007) ("For the defense of habitation to apply, a defendant need only establish that a trespass has occurred and that his chosen means of ejectment were reasonable under the circumstances.").

2021See State v. Rye, 375 S.C. 119, 124 , 651 S.E.2d 321, 323 (2007) ("For the defense of habitation to apply, a defendant need only establish that a trespass has occurred and that his chosen means of ejectment were reasonable under the circumstances.").

2018Dep't of Transp., 385 S.C. 344, 351 , 683 S.E.2d 818, 822 (Ct. App. 2009) ("To warrant reversal, the party seeking the requested jury charge must demonstrate error and prejudice."); Beverly S. v. Kayla R., 395 S.C. 399, 401-02 , 718 S.E.2d 224, 225-26 (Ct. App. 2011) (holding jury charge issues were not properly before this court when appellant failed to include her request to charge and the entire jury charge in the record on appeal); Hamilton v. Greyhound Lines E., 281 S.C. 442, 444 , 316 S.E.2d 368, 369 (1984) ("The appealing party has the burden of furnishing a sufficient record from which

2018Dep't of Transp., 385 S.C. 344, 351 , 683 S.E.2d 818, 822 (Ct. App. 2009) ("To warrant reversal, the party seeking the requested jury charge must demonstrate error and prejudice."); Beverly S. v. Kayla R., 395 S.C. 399, 401-02 , 718 S.E.2d 224, 225-26 (Ct. App. 2011) (holding jury charge issues were not properly before this court when appellant failed to include her request to charge and the entire jury charge in the record on appeal); Hamilton v. Greyhound Lines E., 281 S.C. 442, 444 , 316 S.E.2d 368, 369 (1984) ("The appealing party has the burden of furnishing a sufficient record from which

2018Dep't of Transp., 385 S.C. 344, 351 , 683 S.E.2d 818, 822 (Ct. App. 2009) ("To warrant reversal, the party seeking the requested jury charge must demonstrate error and prejudice."); Beverly S. v. Kayla R., 395 S.C. 399, 401-02 , 718 S.E.2d 224, 225-26 (Ct. App. 2011) (holding jury charge issues were not properly before this court when appellant failed to include her request to charge and the entire jury charge in the record on appeal); Hamilton v. Greyhound Lines E., 281 S.C. 442, 444 , 316 S.E.2d 368, 369 (1984) ("The appealing party has the burden of furnishing a sufficient record from which

2018Dep't of Transp., 385 S.C. 344, 351 , 683 S.E.2d 818, 822 (Ct. App. 2009) ("To warrant reversal, the party seeking the requested jury charge must demonstrate error and prejudice."); Beverly S. v. Kayla R., 395 S.C. 399, 401-02 , 718 S.E.2d 224, 225-26 (Ct. App. 2011) (holding jury charge issues were not properly before this court when appellant failed to include her request to charge and the entire jury charge in the record on appeal); Hamilton v. Greyhound Lines E., 281 S.C. 442, 444 , 316 S.E.2d 368, 369 (1984) ("The appealing party has the burden of furnishing a sufficient record from which

2018Dep't of Transp., 385 S.C. 344, 351 , 683 S.E.2d 818, 822 (Ct. App. 2009) ("To warrant reversal, the party seeking the requested jury charge must demonstrate error and prejudice."); Beverly S. v. Kayla R., 395 S.C. 399, 401-02 , 718 S.E.2d 224, 225-26 (Ct. App. 2011) (holding jury charge issues were not properly before this court when appellant failed to include her request to charge and the entire jury charge in the record on appeal); Hamilton v. Greyhound Lines E., 281 S.C. 442, 444 , 316 S.E.2d 368, 369 (1984) ("The appealing party has the burden of furnishing a sufficient record from which

2018Dep't of Transp., 385 S.C. 344, 351 , 683 S.E.2d 818, 822 (Ct. App. 2009) ("To warrant reversal, the party seeking the requested jury charge must demonstrate error and prejudice."); Beverly S. v. Kayla R., 395 S.C. 399, 401-02 , 718 S.E.2d 224, 225-26 (Ct. App. 2011) (holding jury charge issues were not properly before this court when appellant failed to include her request to charge and the entire jury charge in the record on appeal); Hamilton v. Greyhound Lines E., 281 S.C. 442, 444 , 316 S.E.2d 368, 369 (1984) ("The appealing party has the burden of furnishing a sufficient record from which

2018Sys., 334 S.C. 488, 497 , 514 S.E.2d 570, 575 (1999) (stating an appellate court reviewing a jury charge for error must review the charge as a whole); Fairchild v. S.C.

2018Sys., 334 S.C. 488, 497 , 514 S.E.2d 570, 575 (1999) (stating an appellate court reviewing a jury charge for error must review the charge as a whole); Fairchild v. S.C.

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016State v. Curry, 406 S.C. 364, 373 , 752 S.E.2d 263, 267 (2013).

2016State v. Curry, 406 S.C. 364, 373 , 752 S.E.2d 263, 267 (2013).

2016As to whether the trial court erred in refusing to instruct the jury on defense of others and the right to act on appearances: State v. Starnes, 340 S.C. 312 , 322- 23, 531 S.E.2d 907, 913 (2000) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have the right to take the life of the assailant in self-defense."); id. ("[I]n order for the trial court to give a defense of others charge, there must be some evidence adduced at trial that the defendant was

2016As to whether the trial court erred in refusing to instruct the jury on defense of others and the right to act on appearances: State v. Starnes, 340 S.C. 312 , 322- 23, 531 S.E.2d 907, 913 (2000) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have the right to take the life of the assailant in self-defense."); id. ("[I]n order for the trial court to give a defense of others charge, there must be some evidence adduced at trial that the defendant was

2016As to whether the trial court erred in refusing to instruct the jury on defense of others and the right to act on appearances: State v. Starnes, 340 S.C. 312 , 322- 23, 531 S.E.2d 907, 913 (2000) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have the right to take the life of the assailant in self-defense."); id. ("[I]n order for the trial court to give a defense of others charge, there must be some evidence adduced at trial that the defendant was

2016As to whether the trial court erred in refusing to instruct the jury on defense of others and the right to act on appearances: State v. Starnes, 340 S.C. 312 , 322- 23, 531 S.E.2d 907, 913 (2000) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have the right to take the life of the assailant in self-defense."); id. ("[I]n order for the trial court to give a defense of others charge, there must be some evidence adduced at trial that the defendant was

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016As to whether the trial court erred in refusing to instruct the jury on defense of others and the right to act on appearances: State v. Starnes, 340 S.C. 312 , 322- 23, 531 S.E.2d 907, 913 (2000) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have the right to take the life of the assailant in self-defense."); id. ("[I]n order for the trial court to give a defense of others charge, there must be some evidence adduced at trial that the defendant was

2016As to whether the trial court erred in refusing to instruct the jury on defense of others and the right to act on appearances: State v. Starnes, 340 S.C. 312 , 322- 23, 531 S.E.2d 907, 913 (2000) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have the right to take the life of the assailant in self-defense."); id. ("[I]n order for the trial court to give a defense of others charge, there must be some evidence adduced at trial that the defendant was

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016As to whether the trial court erred in refusing to instruct the jury on defense of others and the right to act on appearances: State v. Starnes, 340 S.C. 312 , 322- 23, 531 S.E.2d 907, 913 (2000) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have the right to take the life of the assailant in self-defense."); id. ("[I]n order for the trial court to give a defense of others charge, there must be some evidence adduced at trial that the defendant was

2016As to whether the trial court erred in refusing to instruct the jury on defense of others and the right to act on appearances: State v. Starnes, 340 S.C. 312 , 322- 23, 531 S.E.2d 907, 913 (2000) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have the right to take the life of the assailant in self-defense."); id. ("[I]n order for the trial court to give a defense of others charge, there must be some evidence adduced at trial that the defendant was

2016As to whether the trial court erred in refusing to instruct the jury on defense of others and the right to act on appearances: State v. Starnes, 340 S.C. 312 , 322- 23, 531 S.E.2d 907, 913 (2000) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have the right to take the life of the assailant in self-defense."); id. ("[I]n order for the trial court to give a defense of others charge, there must be some evidence adduced at trial that the defendant was

2016As to whether the trial court erred in refusing to instruct the jury on defense of others and the right to act on appearances: State v. Starnes, 340 S.C. 312 , 322- 23, 531 S.E.2d 907, 913 (2000) ("Under the theory of defense of others, one is not guilty of taking the life of an assailant who assaults a friend, relative, or bystander if that friend, relative, or bystander would likewise have the right to take the life of the assailant in self-defense."); id. ("[I]n order for the trial court to give a defense of others charge, there must be some evidence adduced at trial that the defendant was

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2016As to whether the trial court erred in refusing to instruct the jury on involuntary manslaughter: Sheppard v. State, 357 S.C. 646, 665 , 594 S.E.2d 462, 472 (2004) ("[T]he trial court is required to charge only the current and correct law of South Carolina); id. at 665 , 594 S.E.2d at 472-73 ("A jury charge is correct if it contains the correct definition of the law when read as a whole."); State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003) (stating that in reviewing a jury charge for error, this court must consider the trial court's jury charge as a whole in light of the

2015We affirm.1 "Generally, the trial [court] is required to charge only the current and correct law of South Carolina." State v. Zeigler, 364 S.C. 94, 106 , 610 S.E.2d 859, 865 (Ct. App. 2005).

2015We affirm.1 "Generally, the trial [court] is required to charge only the current and correct law of South Carolina." State v. Zeigler, 364 S.C. 94, 106 , 610 S.E.2d 859, 865 (Ct. App. 2005).

2014See Welch v. Epstein, 342 S.C. 279, 311 , 536 S.E.2d 408, 425 (Ct. App. 2000) (stating that when reviewing a jury charge for error, the appellate court must review the charge as a whole considering evidence and issues presented); Daves v. Cleary, 355 S.C. 216, 224 , 584 S.E.2d 423, 427 (Ct. App. 2003) (providing the court's refusal to give a requested charge is reversible error only if the requesting party can show prejudice from the refusal).

2014See Welch v. Epstein, 342 S.C. 279, 311 , 536 S.E.2d 408, 425 (Ct. App. 2000) (stating that when reviewing a jury charge for error, the appellate court must review the charge as a whole considering evidence and issues presented); Daves v. Cleary, 355 S.C. 216, 224 , 584 S.E.2d 423, 427 (Ct. App. 2003) (providing the court's refusal to give a requested charge is reversible error only if the requesting party can show prejudice from the refusal).