Williams motion in South Carolina

2015States, however, “still possess a wide latitude of discretion in the matter, and ... their enactments transcend the limitation only where the penalty prescribed is so severe and oppressive as to be wholly disproportioned to the offense and obviously unreasonable.” Id. at 66-67 , 40 S.Ct. 71 (citations omitted); see also Shipman v. Du Pre, 222 S.C. 475 , 480, 73 S.E.2d 716 , 718 (1952) (embracing the Williams standard).

2015States, however, “still possess a wide latitude of discretion in the matter, and ... their enactments transcend the limitation only where the penalty prescribed is so severe and oppressive as to be wholly disproportioned to the offense and obviously unreasonable.” Id. at 66-67 , 40 S.Ct. 71 (citations omitted); see also Shipman v. Du Pre, 222 S.C. 475 , 480, 73 S.E.2d 716 , 718 (1952) (embracing the Williams standard).

2024See State v. Kennedy, 339 S.C. 243, 249 , 528 S.E.2d 700, 703 (Ct. App. 2000) (per curiam) ("The Sixth and Fourteenth Amendments to the United States Constitution and Article 1, Section 14 of the South Carolina Constitution provide that a criminal defendant is entitled to a speedy trial."); see also State v. Brazell, 325 S.C. 65, 75 , 480 S.E.2d 64, 70 (1997) ("Whether or not a person accused of a crime has been denied his constitutional right to a speedy trial is a question to be answered in the light of the circumstances of each case." (quoting State v. Dukes, 256 S.C. 218, 222 , 182 S.E.2d

2024See State v. Kennedy, 339 S.C. 243, 249 , 528 S.E.2d 700, 703 (Ct. App. 2000) (per curiam) ("The Sixth and Fourteenth Amendments to the United States Constitution and Article 1, Section 14 of the South Carolina Constitution provide that a criminal defendant is entitled to a speedy trial."); see also State v. Brazell, 325 S.C. 65, 75 , 480 S.E.2d 64, 70 (1997) ("Whether or not a person accused of a crime has been denied his constitutional right to a speedy trial is a question to be answered in the light of the circumstances of each case." (quoting State v. Dukes, 256 S.C. 218, 222 , 182 S.E.2d

2024See State v. Butler, 407 S.C. 376, 381 , 755 S.E.2d 457, 460 (2014) ("On appeal from the denial of a directed verdict, [appellate courts] view[] the evidence and all reasonable inferences in the light most favorable to the State."); id. ("If there is any direct evidence or any substantial circumstantial evidence reasonably tending to prove the guilt of the accused, the [appellate court] must find the case was properly submitted to the jury." (quoting State v. Weston, 367 S.C. 279 , 292–93, 625 S.E.2d 641, 648 (2006))); see also State v. Bennett, 415 S.C. 232 , 236– 37, 781 S.E.2d 352, 354 (201

2024See State v. Butler, 407 S.C. 376, 381 , 755 S.E.2d 457, 460 (2014) ("On appeal from the denial of a directed verdict, [appellate courts] view[] the evidence and all reasonable inferences in the light most favorable to the State."); id. ("If there is any direct evidence or any substantial circumstantial evidence reasonably tending to prove the guilt of the accused, the [appellate court] must find the case was properly submitted to the jury." (quoting State v. Weston, 367 S.C. 279 , 292–93, 625 S.E.2d 641, 648 (2006))); see also State v. Bennett, 415 S.C. 232 , 236– 37, 781 S.E.2d 352, 354 (201

2024See State v. Butler, 407 S.C. 376, 381 , 755 S.E.2d 457, 460 (2014) ("On appeal from the denial of a directed verdict, [appellate courts] view[] the evidence and all reasonable inferences in the light most favorable to the State."); id. ("If there is any direct evidence or any substantial circumstantial evidence reasonably tending to prove the guilt of the accused, the [appellate court] must find the case was properly submitted to the jury." (quoting State v. Weston, 367 S.C. 279 , 292–93, 625 S.E.2d 641, 648 (2006))); see also State v. Bennett, 415 S.C. 232 , 236– 37, 781 S.E.2d 352, 354 (201

2024See State v. Butler, 407 S.C. 376, 381 , 755 S.E.2d 457, 460 (2014) ("On appeal from the denial of a directed verdict, [appellate courts] view[] the evidence and all reasonable inferences in the light most favorable to the State."); id. ("If there is any direct evidence or any substantial circumstantial evidence reasonably tending to prove the guilt of the accused, the [appellate court] must find the case was properly submitted to the jury." (quoting State v. Weston, 367 S.C. 279 , 292–93, 625 S.E.2d 641, 648 (2006))); see also State v. Bennett, 415 S.C. 232 , 236– 37, 781 S.E.2d 352, 354 (201

2024See State v. Butler, 407 S.C. 376, 381 , 755 S.E.2d 457, 460 (2014) ("On appeal from the denial of a directed verdict, [appellate courts] view[] the evidence and all reasonable inferences in the light most favorable to the State."); id. ("If there is any direct evidence or any substantial circumstantial evidence reasonably tending to prove the guilt of the accused, the [appellate court] must find the case was properly submitted to the jury." (quoting State v. Weston, 367 S.C. 279 , 292–93, 625 S.E.2d 641, 648 (2006))); see also State v. Bennett, 415 S.C. 232 , 236– 37, 781 S.E.2d 352, 354 (201

2024See State v. Butler, 407 S.C. 376, 381 , 755 S.E.2d 457, 460 (2014) ("On appeal from the denial of a directed verdict, [appellate courts] view[] the evidence and all reasonable inferences in the light most favorable to the State."); id. ("If there is any direct evidence or any substantial circumstantial evidence reasonably tending to prove the guilt of the accused, the [appellate court] must find the case was properly submitted to the jury." (quoting State v. Weston, 367 S.C. 279 , 292–93, 625 S.E.2d 641, 648 (2006))); see also State v. Bennett, 415 S.C. 232 , 236– 37, 781 S.E.2d 352, 354 (201

2024See State v. Butler, 407 S.C. 376, 381 , 755 S.E.2d 457, 460 (2014) ("On appeal from the denial of a directed verdict, [appellate courts] view[] the evidence and all reasonable inferences in the light most favorable to the State."); id. ("If there is any direct evidence or any substantial circumstantial evidence reasonably tending to prove the guilt of the accused, the [appellate court] must find the case was properly submitted to the jury." (quoting State v. Weston, 367 S.C. 279 , 292–93, 625 S.E.2d 641, 648 (2006))); see also State v. Bennett, 415 S.C. 232 , 236– 37, 781 S.E.2d 352, 354 (201

2024See State v. Butler, 407 S.C. 376, 381 , 755 S.E.2d 457, 460 (2014) ("On appeal from the denial of a directed verdict, [appellate courts] view[] the evidence and all reasonable inferences in the light most favorable to the State."); id. ("If there is any direct evidence or any substantial circumstantial evidence reasonably tending to prove the guilt of the accused, the [appellate court] must find the case was properly submitted to the jury." (quoting State v. Weston, 367 S.C. 279 , 292–93, 625 S.E.2d 641, 648 (2006))); see also State v. Bennett, 415 S.C. 232 , 236– 37, 781 S.E.2d 352, 354 (201

2024See State v. Kennedy, 339 S.C. 243, 249 , 528 S.E.2d 700, 703 (Ct. App. 2000) (per curiam) ("The Sixth and Fourteenth Amendments to the United States Constitution and Article 1, Section 14 of the South Carolina Constitution provide that a criminal defendant is entitled to a speedy trial."); see also State v. Brazell, 325 S.C. 65, 75 , 480 S.E.2d 64, 70 (1997) ("Whether or not a person accused of a crime has been denied his constitutional right to a speedy trial is a question to be answered in the light of the circumstances of each case." (quoting State v. Dukes, 256 S.C. 218, 222 , 182 S.E.2d

2024See State v. Kennedy, 339 S.C. 243, 249 , 528 S.E.2d 700, 703 (Ct. App. 2000) (per curiam) ("The Sixth and Fourteenth Amendments to the United States Constitution and Article 1, Section 14 of the South Carolina Constitution provide that a criminal defendant is entitled to a speedy trial."); see also State v. Brazell, 325 S.C. 65, 75 , 480 S.E.2d 64, 70 (1997) ("Whether or not a person accused of a crime has been denied his constitutional right to a speedy trial is a question to be answered in the light of the circumstances of each case." (quoting State v. Dukes, 256 S.C. 218, 222 , 182 S.E.2d

2024See State v. Kennedy, 339 S.C. 243, 249 , 528 S.E.2d 700, 703 (Ct. App. 2000) (per curiam) ("The Sixth and Fourteenth Amendments to the United States Constitution and Article 1, Section 14 of the South Carolina Constitution provide that a criminal defendant is entitled to a speedy trial."); see also State v. Brazell, 325 S.C. 65, 75 , 480 S.E.2d 64, 70 (1997) ("Whether or not a person accused of a crime has been denied his constitutional right to a speedy trial is a question to be answered in the light of the circumstances of each case." (quoting State v. Dukes, 256 S.C. 218, 222 , 182 S.E.2d

2024See State v. Kennedy, 339 S.C. 243, 249 , 528 S.E.2d 700, 703 (Ct. App. 2000) (per curiam) ("The Sixth and Fourteenth Amendments to the United States Constitution and Article 1, Section 14 of the South Carolina Constitution provide that a criminal defendant is entitled to a speedy trial."); see also State v. Brazell, 325 S.C. 65, 75 , 480 S.E.2d 64, 70 (1997) ("Whether or not a person accused of a crime has been denied his constitutional right to a speedy trial is a question to be answered in the light of the circumstances of each case." (quoting State v. Dukes, 256 S.C. 218, 222 , 182 S.E.2d

2024See State v. Kennedy, 339 S.C. 243, 249 , 528 S.E.2d 700, 703 (Ct. App. 2000) (per curiam) ("The Sixth and Fourteenth Amendments to the United States Constitution and Article 1, Section 14 of the South Carolina Constitution provide that a criminal defendant is entitled to a speedy trial."); see also State v. Brazell, 325 S.C. 65, 75 , 480 S.E.2d 64, 70 (1997) ("Whether or not a person accused of a crime has been denied his constitutional right to a speedy trial is a question to be answered in the light of the circumstances of each case." (quoting State v. Dukes, 256 S.C. 218, 222 , 182 S.E.2d

2024See State v. Kennedy, 339 S.C. 243, 249 , 528 S.E.2d 700, 703 (Ct. App. 2000) (per curiam) ("The Sixth and Fourteenth Amendments to the United States Constitution and Article 1, Section 14 of the South Carolina Constitution provide that a criminal defendant is entitled to a speedy trial."); see also State v. Brazell, 325 S.C. 65, 75 , 480 S.E.2d 64, 70 (1997) ("Whether or not a person accused of a crime has been denied his constitutional right to a speedy trial is a question to be answered in the light of the circumstances of each case." (quoting State v. Dukes, 256 S.C. 218, 222 , 182 S.E.2d

2024See State v. Kennedy, 339 S.C. 243, 249 , 528 S.E.2d 700, 703 (Ct. App. 2000) (per curiam) ("The Sixth and Fourteenth Amendments to the United States Constitution and Article 1, Section 14 of the South Carolina Constitution provide that a criminal defendant is entitled to a speedy trial."); see also State v. Brazell, 325 S.C. 65, 75 , 480 S.E.2d 64, 70 (1997) ("Whether or not a person accused of a crime has been denied his constitutional right to a speedy trial is a question to be answered in the light of the circumstances of each case." (quoting State v. Dukes, 256 S.C. 218, 222 , 182 S.E.2d

2022Beck, 447 U.S. at 638 n.14; see also Schad v. Arizona, 501 U.S. 624, 646 (1991) (differentiating Beck from a case in which "the jury . . . was given the option of finding [the defendant] guilty of a lesser included noncapital offense"), overruled on other grounds by Ramos v. Louisiana, 140 S. Ct. 1390 (2020). 7 "Some courts have gone even farther, finding harmless error even when no intermediate instruction was offered." Mata-Medina v. People, 71 P.3d 973, 983 (Colo. 2003) (en banc); id. (noting the Hawaii Supreme Court did not require an intermediate instruction based on the reasoning that "j

2022Beck, 447 U.S. at 638 n.14; see also Schad v. Arizona, 501 U.S. 624, 646 (1991) (differentiating Beck from a case in which "the jury . . . was given the option of finding [the defendant] guilty of a lesser included noncapital offense"), overruled on other grounds by Ramos v. Louisiana, 140 S. Ct. 1390 (2020). 7 "Some courts have gone even farther, finding harmless error even when no intermediate instruction was offered." Mata-Medina v. People, 71 P.3d 973, 983 (Colo. 2003) (en banc); id. (noting the Hawaii Supreme Court did not require an intermediate instruction based on the reasoning that "j

2022Beck, 447 U.S. at 638 n.14; see also Schad v. Arizona, 501 U.S. 624, 646 (1991) (differentiating Beck from a case in which "the jury . . . was given the option of finding [the defendant] guilty of a lesser included noncapital offense"), overruled on other grounds by Ramos v. Louisiana, 140 S. Ct. 1390 (2020). 7 "Some courts have gone even farther, finding harmless error even when no intermediate instruction was offered." Mata-Medina v. People, 71 P.3d 973, 983 (Colo. 2003) (en banc); id. (noting the Hawaii Supreme Court did not require an intermediate instruction based on the reasoning that "j

2022Beck, 447 U.S. at 638 n.14; see also Schad v. Arizona, 501 U.S. 624, 646 (1991) (differentiating Beck from a case in which "the jury . . . was given the option of finding [the defendant] guilty of a lesser included noncapital offense"), overruled on other grounds by Ramos v. Louisiana, 140 S. Ct. 1390 (2020). 7 "Some courts have gone even farther, finding harmless error even when no intermediate instruction was offered." Mata-Medina v. People, 71 P.3d 973, 983 (Colo. 2003) (en banc); id. (noting the Hawaii Supreme Court did not require an intermediate instruction based on the reasoning that "j

2022Beck, 447 U.S. at 638 n.14; see also Schad v. Arizona, 501 U.S. 624, 646 (1991) (differentiating Beck from a case in which "the jury . . . was given the option of finding [the defendant] guilty of a lesser included noncapital offense"), overruled on other grounds by Ramos v. Louisiana, 140 S. Ct. 1390 (2020). 7 "Some courts have gone even farther, finding harmless error even when no intermediate instruction was offered." Mata-Medina v. People, 71 P.3d 973, 983 (Colo. 2003) (en banc); id. (noting the Hawaii Supreme Court did not require an intermediate instruction based on the reasoning that "j

2022Beck, 447 U.S. at 638 n.14; see also Schad v. Arizona, 501 U.S. 624, 646 (1991) (differentiating Beck from a case in which "the jury . . . was given the option of finding [the defendant] guilty of a lesser included noncapital offense"), overruled on other grounds by Ramos v. Louisiana, 140 S. Ct. 1390 (2020). 7 "Some courts have gone even farther, finding harmless error even when no intermediate instruction was offered." Mata-Medina v. People, 71 P.3d 973, 983 (Colo. 2003) (en banc); id. (noting the Hawaii Supreme Court did not require an intermediate instruction based on the reasoning that "j

2022Beck, 447 U.S. at 638 n.14; see also Schad v. Arizona, 501 U.S. 624, 646 (1991) (differentiating Beck from a case in which "the jury . . . was given the option of finding [the defendant] guilty of a lesser included noncapital offense"), overruled on other grounds by Ramos v. Louisiana, 140 S. Ct. 1390 (2020). 7 "Some courts have gone even farther, finding harmless error even when no intermediate instruction was offered." Mata-Medina v. People, 71 P.3d 973, 983 (Colo. 2003) (en banc); id. (noting the Hawaii Supreme Court did not require an intermediate instruction based on the reasoning that "j

2022Beck, 447 U.S. at 638 n.14; see also Schad v. Arizona, 501 U.S. 624, 646 (1991) (differentiating Beck from a case in which "the jury . . . was given the option of finding [the defendant] guilty of a lesser included noncapital offense"), overruled on other grounds by Ramos v. Louisiana, 140 S. Ct. 1390 (2020). 7 "Some courts have gone even farther, finding harmless error even when no intermediate instruction was offered." Mata-Medina v. People, 71 P.3d 973, 983 (Colo. 2003) (en banc); id. (noting the Hawaii Supreme Court did not require an intermediate instruction based on the reasoning that "j

2022Moore v. State, 485 S.W.3d 411, 421-22 (Tenn. 2016).

2022Moore v. State, 485 S.W.3d 411, 421-22 (Tenn. 2016).

2022Beck, 447 U.S. at 638 n.14; see also Schad v. Arizona, 501 U.S. 624, 646 (1991) (differentiating Beck from a case in which "the jury . . . was given the option of finding [the defendant] guilty of a lesser included noncapital offense"), overruled on other grounds by Ramos v. Louisiana, 140 S. Ct. 1390 (2020). 7 "Some courts have gone even farther, finding harmless error even when no intermediate instruction was offered." Mata-Medina v. People, 71 P.3d 973, 983 (Colo. 2003) (en banc); id. (noting the Hawaii Supreme Court did not require an intermediate instruction based on the reasoning that "j

2022Beck, 447 U.S. at 638 n.14; see also Schad v. Arizona, 501 U.S. 624, 646 (1991) (differentiating Beck from a case in which "the jury . . . was given the option of finding [the defendant] guilty of a lesser included noncapital offense"), overruled on other grounds by Ramos v. Louisiana, 140 S. Ct. 1390 (2020). 7 "Some courts have gone even farther, finding harmless error even when no intermediate instruction was offered." Mata-Medina v. People, 71 P.3d 973, 983 (Colo. 2003) (en banc); id. (noting the Hawaii Supreme Court did not require an intermediate instruction based on the reasoning that "j

2021See State v. Irvin, 270 S.C. 539, 545 , 243 S.E.2d 195, 197-98 (1978) ("A motion for a new trial . . . is addressed to the sound discretion of the trial [court]."); State v. Harris, 391 S.C. 539, 545 , 706 S.E.2d 526, 529 (Ct. App. 2011) ("[T]his court will affirm the trial court's denial of [a new trial] motion unless the trial court abused its discretion.").

2021See State v. Irvin, 270 S.C. 539, 545 , 243 S.E.2d 195, 197-98 (1978) ("A motion for a new trial . . . is addressed to the sound discretion of the trial [court]."); State v. Harris, 391 S.C. 539, 545 , 706 S.E.2d 526, 529 (Ct. App. 2011) ("[T]his court will affirm the trial court's denial of [a new trial] motion unless the trial court abused its discretion.").

2021See State v. Irvin, 270 S.C. 539, 545 , 243 S.E.2d 195, 197-98 (1978) ("A motion for a new trial . . . is addressed to the sound discretion of the trial [court]."); State v. Harris, 391 S.C. 539, 545 , 706 S.E.2d 526, 529 (Ct. App. 2011) ("[T]his court will affirm the trial court's denial of [a new trial] motion unless the trial court abused its discretion.").

2021See State v. Irvin, 270 S.C. 539, 545 , 243 S.E.2d 195, 197-98 (1978) ("A motion for a new trial . . . is addressed to the sound discretion of the trial [court]."); State v. Harris, 391 S.C. 539, 545 , 706 S.E.2d 526, 529 (Ct. App. 2011) ("[T]his court will affirm the trial court's denial of [a new trial] motion unless the trial court abused its discretion.").

2020See Rule 29(b), SCRCrimP (allowing a criminal defendant to move for a new trial based on after-discovered evidence); State v. Mercer, 381 S.C. 149, 166 , 672 S.E.2d 556, 565 (2009) ("The decision whether to grant a new trial rests within the sound discretion of the trial court, and [the appellate court] will not disturb the trial court's decision absent an abuse of discretion."); State v. Cartwright, 425 S.C. 81, 89-90 , 819 S.E.2d 756, 760 (2018) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law." (quot

2020See Rule 29(b), SCRCrimP (allowing a criminal defendant to move for a new trial based on after-discovered evidence); State v. Mercer, 381 S.C. 149, 166 , 672 S.E.2d 556, 565 (2009) ("The decision whether to grant a new trial rests within the sound discretion of the trial court, and [the appellate court] will not disturb the trial court's decision absent an abuse of discretion."); State v. Cartwright, 425 S.C. 81, 89-90 , 819 S.E.2d 756, 760 (2018) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law." (quot

2020See Rule 29(b), SCRCrimP (allowing a criminal defendant to move for a new trial based on after-discovered evidence); State v. Mercer, 381 S.C. 149, 166 , 672 S.E.2d 556, 565 (2009) ("The decision whether to grant a new trial rests within the sound discretion of the trial court, and [the appellate court] will not disturb the trial court's decision absent an abuse of discretion."); State v. Cartwright, 425 S.C. 81, 89-90 , 819 S.E.2d 756, 760 (2018) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law." (quot

2020See Rule 29(b), SCRCrimP (allowing a criminal defendant to move for a new trial based on after-discovered evidence); State v. Mercer, 381 S.C. 149, 166 , 672 S.E.2d 556, 565 (2009) ("The decision whether to grant a new trial rests within the sound discretion of the trial court, and [the appellate court] will not disturb the trial court's decision absent an abuse of discretion."); State v. Cartwright, 425 S.C. 81, 89-90 , 819 S.E.2d 756, 760 (2018) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law." (quot

2020See United States v. Weaver, 282 F.3d 302, 312 (4th Cir. 2002) ("Unlike those situations that may occur in the traffic stop context, pedestrian encounters are much less restrictive of an individual's movements."). - The number of officers present and whether they were uniformed: Three plain-clothed agents spoke with Spears and Jenkins. - The length of the detention: The record is not clear as to the exact length; Jenkins was unsure but believed the detention likely lasted less than twenty minutes; in this case, that is not an excessive length of time. - Whether the officer moved the person to

2020See United States v. Weaver, 282 F.3d 302, 312 (4th Cir. 2002) ("Unlike those situations that may occur in the traffic stop context, pedestrian encounters are much less restrictive of an individual's movements."). - The number of officers present and whether they were uniformed: Three plain-clothed agents spoke with Spears and Jenkins. - The length of the detention: The record is not clear as to the exact length; Jenkins was unsure but believed the detention likely lasted less than twenty minutes; in this case, that is not an excessive length of time. - Whether the officer moved the person to

2020See Rule 29(b), SCRCrimP (allowing a criminal defendant to move for a new trial based on after-discovered evidence); State v. Mercer, 381 S.C. 149, 166 , 672 S.E.2d 556, 565 (2009) ("The decision whether to grant a new trial rests within the sound discretion of the trial court, and [the appellate court] will not disturb the trial court's decision absent an abuse of discretion."); State v. Cartwright, 425 S.C. 81, 89-90 , 819 S.E.2d 756, 760 (2018) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law." (quot

2020See Rule 29(b), SCRCrimP (allowing a criminal defendant to move for a new trial based on after-discovered evidence); State v. Mercer, 381 S.C. 149, 166 , 672 S.E.2d 556, 565 (2009) ("The decision whether to grant a new trial rests within the sound discretion of the trial court, and [the appellate court] will not disturb the trial court's decision absent an abuse of discretion."); State v. Cartwright, 425 S.C. 81, 89-90 , 819 S.E.2d 756, 760 (2018) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law." (quot

2018As to whether the trial court erred by overruling Williams's objection to the victim's testimony: State v. Fletcher, 379 S.C. 17, 25 , 664 S.E.2d 480, 484 (2008) ("Error is harmless beyond a reasonable doubt [when] it did not contribute to the verdict obtained."); State v. Adams, 354 S.C. 361, 380-81 , 580 S.E.2d 785, 795 (Ct. App. 2003) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result."); 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 [

2018As to whether the trial court erred by overruling Williams's objection to the victim's testimony: State v. Fletcher, 379 S.C. 17, 25 , 664 S.E.2d 480, 484 (2008) ("Error is harmless beyond a reasonable doubt [when] it did not contribute to the verdict obtained."); State v. Adams, 354 S.C. 361, 380-81 , 580 S.E.2d 785, 795 (Ct. App. 2003) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result."); 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 [

2018As to whether the trial court erred by denying Williams's motion for a mistrial: State v. Harris, 382 S.C. 107, 117 , 674 S.E.2d 532, 537 (Ct. App. 2009) ("The decision to grant or deny a mistrial is within the sound discretion of the trial court."); id. ("A mistrial should only be granted when absolutely necessary, and a defendant must show both error and resulting prejudice in order to be entitled to a mistrial."); id. ("The granting of a motion for a mistrial is an extreme measure that should only be taken if an incident is so grievous that the prejudicial effect can be removed in no other

2018As to whether the trial court erred by denying Williams's motion for a mistrial: State v. Harris, 382 S.C. 107, 117 , 674 S.E.2d 532, 537 (Ct. App. 2009) ("The decision to grant or deny a mistrial is within the sound discretion of the trial court."); id. ("A mistrial should only be granted when absolutely necessary, and a defendant must show both error and resulting prejudice in order to be entitled to a mistrial."); id. ("The granting of a motion for a mistrial is an extreme measure that should only be taken if an incident is so grievous that the prejudicial effect can be removed in no other

2018As to whether the trial court erred by overruling Williams's objection to the victim's testimony: State v. Fletcher, 379 S.C. 17, 25 , 664 S.E.2d 480, 484 (2008) ("Error is harmless beyond a reasonable doubt [when] it did not contribute to the verdict obtained."); State v. Adams, 354 S.C. 361, 380-81 , 580 S.E.2d 785, 795 (Ct. App. 2003) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result."); 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 [

2018As to whether the trial court erred by overruling Williams's objection to the victim's testimony: State v. Fletcher, 379 S.C. 17, 25 , 664 S.E.2d 480, 484 (2008) ("Error is harmless beyond a reasonable doubt [when] it did not contribute to the verdict obtained."); State v. Adams, 354 S.C. 361, 380-81 , 580 S.E.2d 785, 795 (Ct. App. 2003) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result."); 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 [

2018As to whether the trial court erred by overruling Williams's objection to the victim's testimony: State v. Fletcher, 379 S.C. 17, 25 , 664 S.E.2d 480, 484 (2008) ("Error is harmless beyond a reasonable doubt [when] it did not contribute to the verdict obtained."); State v. Adams, 354 S.C. 361, 380-81 , 580 S.E.2d 785, 795 (Ct. App. 2003) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result."); 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 [

2018As to whether the trial court erred by overruling Williams's objection to the victim's testimony: State v. Fletcher, 379 S.C. 17, 25 , 664 S.E.2d 480, 484 (2008) ("Error is harmless beyond a reasonable doubt [when] it did not contribute to the verdict obtained."); State v. Adams, 354 S.C. 361, 380-81 , 580 S.E.2d 785, 795 (Ct. App. 2003) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result."); 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 [