reasonable doubt error in South Carolina

2026See Brown, 438 S.C. at 151, S.E.2d at 773 ("In order to find the error harmless, we must determine beyond a reasonable doubt that the error complained of did not contribute to the verdict." (quoting Kerr, 330 S.C. at 144–45, 498 S.E.2d at 218 )).

2026See Brown, 438 S.C. at 151, S.E.2d at 773 ("In order to find the error harmless, we must determine beyond a reasonable doubt that the error complained of did not contribute to the verdict." (quoting Kerr, 330 S.C. at 144–45, 498 S.E.2d at 218 )).

2026See Campbell, 443 S.C. at 191, 904 S.E. 2d at 445 ("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 State v. Middleton, 407 S.C. 312, 317 , 755 S.E.2d 432, 435 (2014))). 4 Mutual combat can also be applied to attempted murder charges.

2026See Campbell, 443 S.C. at 191, 904 S.E. 2d at 445 ("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 State v. Middleton, 407 S.C. 312, 317 , 755 S.E.2d 432, 435 (2014))). 4 Mutual combat can also be applied to attempted murder charges.

2022See State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) (stating, "The key factor for determining whether a trial error constitutes reversible error is whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained" (internal quotation marks omitted) (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993))).3 If we have any reasonable doubt as to whether the erroneous charge contributed to the verdict, we must affirm the reversal of the conviction.

2022See State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) (stating, "The key factor for determining whether a trial error constitutes reversible error is whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained" (internal quotation marks omitted) (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993))).3 If we have any reasonable doubt as to whether the erroneous charge contributed to the verdict, we must affirm the reversal of the conviction.

2022See State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) (stating, "The key factor for determining whether a trial error constitutes reversible error is whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained" (internal quotation marks omitted) (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993))).3 If we have any reasonable doubt as to whether the erroneous charge contributed to the verdict, we must affirm the reversal of the conviction.

2022See State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) (stating, "The key factor for determining whether a trial error constitutes reversible error is whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained" (internal quotation marks omitted) (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993))).3 If we have any reasonable doubt as to whether the erroneous charge contributed to the verdict, we must affirm the reversal of the conviction.

2014In State v. Creech, 314 S.C. 76 , 441 S.E.2d 635 (Ct.App. 1993), this court reiterated the Supreme Court of the United States’ holding in Chapman v. California 4 that error of even constitutional magnitude may be deemed harmless if, “considering the entire record on appeal, the reviewing court finds beyond a reasonable doubt that the error did not contribute to the verdict.” Id. at 86 , 441 S.E.2d at 640 (citing Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967)); see also Taylor v. State, 312 S.C. 179, 181 , 439 S.E.2d 820, 821 (1993).

2014In State v. Creech, 314 S.C. 76 , 441 S.E.2d 635 (Ct.App. 1993), this court reiterated the Supreme Court of the United States’ holding in Chapman v. California 4 that error of even constitutional magnitude may be deemed harmless if, “considering the entire record on appeal, the reviewing court finds beyond a reasonable doubt that the error did not contribute to the verdict.” Id. at 86 , 441 S.E.2d at 640 (citing Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967)); see also Taylor v. State, 312 S.C. 179, 181 , 439 S.E.2d 820, 821 (1993).

2012The trial court also instructed the jury that the defendant’s guilt must be proved beyond a reasonable doubt and specifically advised that the State must prove “beyond a reasonable doubt the identity of the defendant as the perpetrator of the offenses with which he stands charged.” Having thoroughly reviewed the record, we can say with assurance that “it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Lowry v. State, 376 S.C. 499, 507 , 657 S.E.2d 760, 764 (2008) (quoting Arnold v. State, 309 S.C. 157, 165 , 420 S.E.2d 834, 838 (1992)

2012The trial court also instructed the jury that the defendant’s guilt must be proved beyond a reasonable doubt and specifically advised that the State must prove “beyond a reasonable doubt the identity of the defendant as the perpetrator of the offenses with which he stands charged.” Having thoroughly reviewed the record, we can say with assurance that “it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Lowry v. State, 376 S.C. 499, 507 , 657 S.E.2d 760, 764 (2008) (quoting Arnold v. State, 309 S.C. 157, 165 , 420 S.E.2d 834, 838 (1992)

2023See State v. Aleksey, 343 S.C. 20, 26-29 , 538 S.E.2d 248, 251-53 (2000) (holding the trial court's instructions to the jury that it had "one single objective and that [was] to seek the truth" in the context of the court's instructions as a whole, which included full instructions regarding reasonable doubt, did not violate the defendant's constitutional rights); State v. Daniels, 401 S.C. 251, 257, 260 , 737 S.E.2d 473, 476-77 (2012) (Toal, C.J., concurring) (finding the trial court stating "[t]his court is of the confirmed opinion that whatever verdict you reach will represent truth and justi

2023See State v. Aleksey, 343 S.C. 20, 26-29 , 538 S.E.2d 248, 251-53 (2000) (holding the trial court's instructions to the jury that it had "one single objective and that [was] to seek the truth" in the context of the court's instructions as a whole, which included full instructions regarding reasonable doubt, did not violate the defendant's constitutional rights); State v. Daniels, 401 S.C. 251, 257, 260 , 737 S.E.2d 473, 476-77 (2012) (Toal, C.J., concurring) (finding the trial court stating "[t]his court is of the confirmed opinion that whatever verdict you reach will represent truth and justi

2025"If the government can show 'beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained,' . . . then the error is deemed harmless and the defendant is not entitled to reversal." Id. (quoting Chapman v. California, 386 U.S. 18, 24 (1967)).

2014In State v. Creech, 314 S.C. 76 , 441 S.E.2d 635 (Ct.App. 1993), this court reiterated the Supreme Court of the United States’ holding in Chapman v. California 4 that error of even constitutional magnitude may be deemed harmless if, “considering the entire record on appeal, the reviewing court finds beyond a reasonable doubt that the error did not contribute to the verdict.” Id. at 86 , 441 S.E.2d at 640 (citing Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967)); see also Taylor v. State, 312 S.C. 179, 181 , 439 S.E.2d 820, 821 (1993).

2017LOCKEMY, C.J., and KONDUROS and MCDONALD, JJ., concur. 3 State v. Grippon, 327 S.C. 79, 83-84 , 489 S.E.2d 462, 464 (1997) (recommending a charge for the trial court to give the jury on circumstantial evidence and noting that once the trial court gives a proper reasonable doubt instruction, it need not inform a jury the circumstantial evidence must be so strong as to exclude every reasonable hypothesis other than guilt).

2017LOCKEMY, C.J., and KONDUROS and MCDONALD, JJ., concur. 3 State v. Grippon, 327 S.C. 79, 83-84 , 489 S.E.2d 462, 464 (1997) (recommending a charge for the trial court to give the jury on circumstantial evidence and noting that once the trial court gives a proper reasonable doubt instruction, it need not inform a jury the circumstantial evidence must be so strong as to exclude every reasonable hypothesis other than guilt).

2021See State v. Huggins, 336 S.C. 200, 204 , 519 S.E.2d 574, 576 (1999) ("Error without prejudice does not warrant reversal."); State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) ("The key factor for determining whether a trial error constitutes reversible error is 'whether it appears "beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained."'" (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993) (Goolsby A.J., concurring))); State v. King, 424 S.C. 188, 201 , 818 S.E.2d 204, 211 (2018) ("[A]n insubstantial error not affecti

2021See State v. Huggins, 336 S.C. 200, 204 , 519 S.E.2d 574, 576 (1999) ("Error without prejudice does not warrant reversal."); State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) ("The key factor for determining whether a trial error constitutes reversible error is 'whether it appears "beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained."'" (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993) (Goolsby A.J., concurring))); State v. King, 424 S.C. 188, 201 , 818 S.E.2d 204, 211 (2018) ("[A]n insubstantial error not affecti

2015Compare State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) ("The key factor for determining whether a trial error constitutes reversible error is 'whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.' ” (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993))), with State v. Bryant, 369 S.C. 511, 518 , 633 S.E.2d 152, 156 (2006) ("[A]n insubstantial error not affecting the result of the trial is harmless where a defendant’s guilt has been conclusively proven by competent evidence such that no other rat

2015Compare State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) ("The key factor for determining whether a trial error constitutes reversible error is 'whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.' ” (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993))), with State v. Bryant, 369 S.C. 511, 518 , 633 S.E.2d 152, 156 (2006) ("[A]n insubstantial error not affecting the result of the trial is harmless where a defendant’s guilt has been conclusively proven by competent evidence such that no other rat

2013See id. at 55, 625 S.E.2d at 223 (2006) ("When guilt is conclusively proven by competent evidence, such that no other rational conclusion could be reached, this Court will not set aside a conviction for insubstantial errors not affecting the result."); Taylor v. State, 312 S.C. 179, 181 , 439 S.E.2d 820, 821 (1993) ("For the error to be harmless, we must determine 'beyond a reasonable doubt the error complained of did not contribute to the verdict obtained.'" (quoting Chapman v. California, 386 U.S. 18 (1967))).

2012“To deem an error harmless, this court must determine ‘beyond a reasonable doubt the error complained of did not contribute to the verdict obtained.’ ” State v. Fonseca, 383 S.C. 640, 650 , 681 S.E.2d 1, 6 (Ct.App.2009) (quoting Taylor v. State, 312 S.C. 179, 181 , 439 S.E.2d 820, 821 (1993)), aff'd, 393 S.C. 229 , 711 S.E.2d 906 (2011); see also Baccus, 367 S.C. at 55 , 625 S.E.2d at 223 (“When guilt is conclusively proven by competent evidence, such that no other rational conclusion could be reached, this Court will not set aside a conviction for insubstantial errors not affecting the result

2021See State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) ("The key factor for determining whether a trial error constitutes reversible error is whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained."); State v. Mitchell, 286 S.C. 572, 573 , 336 S.E.2d 150, 151 (1985) ("[T]he materiality and prejudicial character of [an] error [regarding the admission of evidence] must be determined from its relationship to the entire case.").

2021See State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) ("The key factor for determining whether a trial error constitutes reversible error is whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained."); State v. Mitchell, 286 S.C. 572, 573 , 336 S.E.2d 150, 151 (1985) ("[T]he materiality and prejudicial character of [an] error [regarding the admission of evidence] must be determined from its relationship to the entire case.").

2025"In reviewing jury charges for error, we must consider the court's jury charge as a whole in light of the evidence and issues presented at trial." Perry, 440 S.C. at 403, 892 S.E.2d at 276– 77 (quoting State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003)).

2025"In reviewing jury charges for error, we must consider the court's jury charge as a whole in light of the evidence and issues presented at trial." Perry, 440 S.C. at 403, 892 S.E.2d at 276– 77 (quoting State v. Adkins, 353 S.C. 312, 318 , 577 S.E.2d 460, 463 (Ct. App. 2003)).

2021See State v. Huggins, 336 S.C. 200, 204 , 519 S.E.2d 574, 576 (1999) ("Error without prejudice does not warrant reversal."); State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) ("The key factor for determining whether a trial error constitutes reversible error is 'whether it appears "beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained."'" (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993) (Goolsby A.J., concurring))); State v. King, 424 S.C. 188, 201 , 818 S.E.2d 204, 211 (2018) ("[A]n insubstantial error not affecti

2021See State v. Huggins, 336 S.C. 200, 204 , 519 S.E.2d 574, 576 (1999) ("Error without prejudice does not warrant reversal."); State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) ("The key factor for determining whether a trial error constitutes reversible error is 'whether it appears "beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained."'" (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993) (Goolsby A.J., concurring))); State v. King, 424 S.C. 188, 201 , 818 S.E.2d 204, 211 (2018) ("[A]n insubstantial error not affecti

2019"Whether an error is harmless depends on the circumstances of the particular case." Id. (citing State v. Mitchell, 378 S.C. 305, 316 , 662 S.E.2d 493, 499 (Ct. App. 2008)).

2019"Whether an error is harmless depends on the circumstances of the particular case." Id. (citing State v. Mitchell, 378 S.C. 305, 316 , 662 S.E.2d 493, 499 (Ct. App. 2008)).

2016See State v. Belcher, 385 S.C. 597, 611 , 685 S.E.2d 802, 809 (2009) ("Errors, including erroneous jury instructions, are subject to harmless error analysis."); State v. Middleton, 407 S.C. 312, 317 , 755 S.E.2d 432, 435 (2014) ("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." (internal quotation marks omitted)).

2016See State v. Belcher, 385 S.C. 597, 611 , 685 S.E.2d 802, 809 (2009) ("Errors, including erroneous jury instructions, are subject to harmless error analysis."); State v. Middleton, 407 S.C. 312, 317 , 755 S.E.2d 432, 435 (2014) ("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." (internal quotation marks omitted)).

2015Compare State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) ("The key factor for determining whether a trial error constitutes reversible error is 'whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.' ” (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993))), with State v. Bryant, 369 S.C. 511, 518 , 633 S.E.2d 152, 156 (2006) ("[A]n insubstantial error not affecting the result of the trial is harmless where a defendant’s guilt has been conclusively proven by competent evidence such that no other rat

2015Compare State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) ("The key factor for determining whether a trial error constitutes reversible error is 'whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.' ” (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993))), with State v. Bryant, 369 S.C. 511, 518 , 633 S.E.2d 152, 156 (2006) ("[A]n insubstantial error not affecting the result of the trial is harmless where a defendant’s guilt has been conclusively proven by competent evidence such that no other rat

2015Compare State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) ("The key factor for determining whether a trial error constitutes reversible error is 'whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.' ” (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993))), with State v. Bryant, 369 S.C. 511, 518 , 633 S.E.2d 152, 156 (2006) ("[A]n insubstantial error not affecting the result of the trial is harmless where a defendant’s guilt has been conclusively proven by competent evidence such that no other rat

2015Compare State v. Tapp, 398 S.C. 376, 389 , 728 S.E.2d 468, 475 (2012) ("The key factor for determining whether a trial error constitutes reversible error is 'whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.' ” (quoting State v. Charping, 313 S.C. 147, 157 , 437 S.E.2d 88, 94 (1993))), with State v. Bryant, 369 S.C. 511, 518 , 633 S.E.2d 152, 156 (2006) ("[A]n insubstantial error not affecting the result of the trial is harmless where a defendant’s guilt has been conclusively proven by competent evidence such that no other rat

2012“To deem an error harmless, this court must determine ‘beyond a reasonable doubt the error complained of did not contribute to the verdict obtained.’ ” State v. Fonseca, 383 S.C. 640, 650 , 681 S.E.2d 1, 6 (Ct.App.2009) (quoting Taylor v. State, 312 S.C. 179, 181 , 439 S.E.2d 820, 821 (1993)), aff'd, 393 S.C. 229 , 711 S.E.2d 906 (2011); see also Baccus, 367 S.C. at 55 , 625 S.E.2d at 223 (“When guilt is conclusively proven by competent evidence, such that no other rational conclusion could be reached, this Court will not set aside a conviction for insubstantial errors not affecting the result

2012“To deem an error harmless, this court must determine ‘beyond a reasonable doubt the error complained of did not contribute to the verdict obtained.’ ” State v. Fonseca, 383 S.C. 640, 650 , 681 S.E.2d 1, 6 (Ct.App.2009) (quoting Taylor v. State, 312 S.C. 179, 181 , 439 S.E.2d 820, 821 (1993)), aff'd, 393 S.C. 229 , 711 S.E.2d 906 (2011); see also Baccus, 367 S.C. at 55 , 625 S.E.2d at 223 (“When guilt is conclusively proven by competent evidence, such that no other rational conclusion could be reached, this Court will not set aside a conviction for insubstantial errors not affecting the result

2007For the error to be harmless, we must determine “beyond a reasonable doubt the error complained of did not contribute to the verdict obtained.” Taylor, 312 S.C. at 181 , 439 S.E.2d at 821 (citing Arnold, 309 S.C. at 165 , 420 S.E.2d at *415 839); Jefferies, 316 S.C. at 22 , 446 S.E.2d at 432 ; State v. Buckner, 341 S.C. 241, 247 , 534 S.E.2d 15, 18 (Ct.App.2000) (citing State v. Andrews, 324 S.C. 516 , 479 S.E.2d 808 (Ct.App.1996)). “[A]n insubstantial error not affecting the result of the trial is harmless where ‘guilt has been conclusively proven by competent evidence such that no other rati

2007For the error to be harmless, we must determine “beyond a reasonable doubt the error complained of did not contribute to the verdict obtained.” Taylor, 312 S.C. at 181 , 439 S.E.2d at 821 (citing Arnold, 309 S.C. at 165 , 420 S.E.2d at *415 839); Jefferies, 316 S.C. at 22 , 446 S.E.2d at 432 ; State v. Buckner, 341 S.C. 241, 247 , 534 S.E.2d 15, 18 (Ct.App.2000) (citing State v. Andrews, 324 S.C. 516 , 479 S.E.2d 808 (Ct.App.1996)). “[A]n insubstantial error not affecting the result of the trial is harmless where ‘guilt has been conclusively proven by competent evidence such that no other rati

2001Lest there remain any doubt about the constitutional stature of the reasonable-doubt standard, we explicitly hold that the Due Process Clause protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged. [5] See id. at 84, 489 S.E.2d at 465 (citing State v. Raffaldt, 318 S.C. 110 , 456 S.E.2d 390 (1995) and State v. Manning, 305 S.C. 413 , 409 S.E.2d 372 (1991), impliedly overruled on other grounds by State v. Aleksey, 343 S.C. 20 , 538 S.E.2d 248 (2000)).

2001Lest there remain any doubt about the constitutional stature of the reasonable-doubt standard, we explicitly hold that the Due Process Clause protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged. [5] See id. at 84, 489 S.E.2d at 465 (citing State v. Raffaldt, 318 S.C. 110 , 456 S.E.2d 390 (1995) and State v. Manning, 305 S.C. 413 , 409 S.E.2d 372 (1991), impliedly overruled on other grounds by State v. Aleksey, 343 S.C. 20 , 538 S.E.2d 248 (2000)).

2001NOTES [1] We have not factored in nor considered the presence of the pistol in the vehicle because the trial judge, in analyzing whether to submit the case to the jury, specifically stated that he did not consider it in his deliberations. [2] See, e.g., State v. Williams, 35 S.C. 344 , 14 S.E. 819 (1892). [3] 298 S.C. at 274 , 379 S.E.2d at 888 . [4] See 397 U.S. at 361-64 , 90 S.Ct. at 1071 -73 for the Court's analysis of the constitutionality of the reasonable doubt standard: The requirement that guilt of a criminal charge be established by proof beyond a reasonable doubt dates at least from

2001NOTES [1] We have not factored in nor considered the presence of the pistol in the vehicle because the trial judge, in analyzing whether to submit the case to the jury, specifically stated that he did not consider it in his deliberations. [2] See, e.g., State v. Williams, 35 S.C. 344 , 14 S.E. 819 (1892). [3] 298 S.C. at 274 , 379 S.E.2d at 888 . [4] See 397 U.S. at 361-64 , 90 S.Ct. at 1071 -73 for the Court's analysis of the constitutionality of the reasonable doubt standard: The requirement that guilt of a criminal charge be established by proof beyond a reasonable doubt dates at least from

2022See State v. Burdette, 427 S.C. 490 , 496, 832 S.E.2d 575 , 578 (2019) ("An erroneous instruction alone is insufficient to warrant . . . reversal."); State v. Smith, 430 S.C. 226 , 233, 845 S.E.2d 495 , 498 (2020) ("[E]rroneous jury instructions are subject to a harmless error analysis."); State v. Middleton, 407 S.C. 312, 317 , 755 S.E.2d 432, 435 (2014) (holding an erroneous jury instruction is harmless if the court "determine[s] beyond a reasonable doubt that the error complained of did not contribute to the verdict" (quoting State v. Kerr, 330 S.C. 132, 144-45 , 498 S.E.2d 212, 218 (Ct. Ap

2022See State v. Burdette, 427 S.C. 490 , 496, 832 S.E.2d 575 , 578 (2019) ("An erroneous instruction alone is insufficient to warrant . . . reversal."); State v. Smith, 430 S.C. 226 , 233, 845 S.E.2d 495 , 498 (2020) ("[E]rroneous jury instructions are subject to a harmless error analysis."); State v. Middleton, 407 S.C. 312, 317 , 755 S.E.2d 432, 435 (2014) (holding an erroneous jury instruction is harmless if the court "determine[s] beyond a reasonable doubt that the error complained of did not contribute to the verdict" (quoting State v. Kerr, 330 S.C. 132, 144-45 , 498 S.E.2d 212, 218 (Ct. Ap

2019See Yates, 500 U.S. at 403 ("To say that an error did not contribute to the verdict is . . . to find that error unimportant in relation to everything else the jury considered on the issue in question, as revealed in the record." (emphasis added)); 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 Middleton, 407 S.C. at 317 , 755 S.E.2d at 435 )).

1995Having reached this conclusion, we must now determine whether “ ‘beyond a reasonable doubt the error complained of did not contribute to the verdict obtained.’ ” Arnold v. State, 309 S.C. 157, 165 , 420 S.E. (2d) 834, 839 (1992) (quoting Chapman v. California, 386 U.S. 18, 23 , 87 S.Ct. 824, 827 , 17 L.Ed. (2d) 705 (1967)), cert, denied, — U.S. —, 113 S.Ct. 1302 , 122 L.Ed. (2d) 691 (1993). “ ‘[The] requirement that harmlessness of federal constitutional error be clear beyond a reasonable doubt embodies [a] standard requiring reversal if there is a reasonable possibility that the evidence comp

2015Id. at 601 , 606 S.E.2d at 482 (footnotes omitted).

2013Thus, the Court held the Grippon language as “the sole and exclusive charge to be given in circumstantial evidence cases in this state, along with a proper reasonable doubt instruction.” Id.

2014See State v. Jones, 343 S.C. 562, 578 , 541 S.E.2d 813, 821 (2001) (holding a jury instruction explaining, “A reasonable doubt is the kind of doubt that would cause a reasonable person to hesitate to act” was “a correct statement of South Carolina law.”).

2014See State v. Jones, 343 S.C. 562, 578 , 541 S.E.2d 813, 821 (2001) (holding a jury instruction explaining, “A reasonable doubt is the kind of doubt that would cause a reasonable person to hesitate to act” was “a correct statement of South Carolina law.”).

2014After a review of the direct appeal issue briefed, whether the trial court erred in denying Petitioner's motion for a mistrial, we affirm pursuant to Rule 220(b), SCACR, and the following authorities: Doyle v. Ohio, 426 U.S. 610, 619 (1976) (holding it is a violation of due process for a defendant's post-Miranda1 silence to be used against him at trial for impeachment purposes); State v. McIntosh, 358 S.C. 432, 447 , 595 S.E.2d 484, 492 (2004) ("When a Doyle violation occurs, the conviction still may be upheld when a review of the entire record establishes beyond a reasonable doubt the error w

2014After a review of the direct appeal issue briefed, whether the trial court erred in denying Petitioner's motion for a mistrial, we affirm pursuant to Rule 220(b), SCACR, and the following authorities: Doyle v. Ohio, 426 U.S. 610, 619 (1976) (holding it is a violation of due process for a defendant's post-Miranda1 silence to be used against him at trial for impeachment purposes); State v. McIntosh, 358 S.C. 432, 447 , 595 S.E.2d 484, 492 (2004) ("When a Doyle violation occurs, the conviction still may be upheld when a review of the entire record establishes beyond a reasonable doubt the error w