insubstantial error in South Carolina

2026State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006) (An insubstantial error that does not affect the result of the trial is considered harmless "where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.'"(quoting State v. Bailey, 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989))).

2026State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006) (An insubstantial error that does not affect the result of the trial is considered harmless "where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.'"(quoting State v. Bailey, 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989))).

2026State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006) (An insubstantial error that does not affect the result of the trial is considered harmless "where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.'"(quoting State v. Bailey, 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989))).

2026State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006) (An insubstantial error that does not affect the result of the trial is considered harmless "where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.'"(quoting State v. Bailey, 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989))).

2018See State v. Adams , 354 S.C. 361 , 380, 580 S.E.2d 785 , 795 (Ct. App. 2003) ("Error is harmless where it could not reasonably have affected the result of the trial."); id. at 381 , 580 S.E.2d at 795 ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result."); id. ("Thus, an insubstantial error not affecting the result of the trial is harmless where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.'" (quoting State v. Bailey , 298 S.C. 1 , 5, 377 S.E.2d 581 , 584 (1989) ) );

2018See State v. Adams , 354 S.C. 361 , 380, 580 S.E.2d 785 , 795 (Ct. App. 2003) ("Error is harmless where it could not reasonably have affected the result of the trial."); id. at 381 , 580 S.E.2d at 795 ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result."); id. ("Thus, an insubstantial error not affecting the result of the trial is harmless where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.'" (quoting State v. Bailey , 298 S.C. 1 , 5, 377 S.E.2d 581 , 584 (1989) ) );

2024See State v. Byers, 392 S.C. 438, 447 , 710 S.E.2d 55, 60 (2011) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result." (quoting State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006))); id. ("Where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached,' an insubstantial error that does not affect the result of the trial is considered harmless." (quoting Pagan, 369 S.C. at 212 , 631 S.E.2d at 267 )).

2024See State v. Byers, 392 S.C. 438, 447 , 710 S.E.2d 55, 60 (2011) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result." (quoting State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006))); id. ("Where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached,' an insubstantial error that does not affect the result of the trial is considered harmless." (quoting Pagan, 369 S.C. at 212 , 631 S.E.2d at 267 )).

2020See State v. Brown, 424 S.C. 479, 493 , 818 S.E.2d 735, 743 (2018) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result." (quoting State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006))); id. ("Where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached,' an insubstantial error that does not affect the result of the trial is considered harmless." (quoting State v. Byers, 392 S.C. 438, 447 , 710 S.E.2d 55, 60 (2011))); id. ("Where a review of the entire record establis

2020See State v. Brown, 424 S.C. 479, 493 , 818 S.E.2d 735, 743 (2018) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result." (quoting State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006))); id. ("Where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached,' an insubstantial error that does not affect the result of the trial is considered harmless." (quoting State v. Byers, 392 S.C. 438, 447 , 710 S.E.2d 55, 60 (2011))); id. ("Where a review of the entire record establis

2016State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006) ("Error is harmless beyond a reasonable doubt where it did not contribute to the verdict obtained."); Bryant, 369 S.C. at 518 , 633 S.E.2d at 156 ("Thus, an 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 rational conclusion can be reached.").

2016State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006) ("Error is harmless beyond a reasonable doubt where it did not contribute to the verdict obtained."); Bryant, 369 S.C. at 518 , 633 S.E.2d at 156 ("Thus, an 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 rational conclusion can be reached.").

2013“Thus, an 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 rational conclusion can be reached.” Id. (citing State v. Bailey, 298 S.C. 1, 4-5 , 377 S.E.2d 581, 583-84 (1989)).

2004State v. Sherard , 303 S.C. 172, 176 , 399 S.E.2d 595, 597 (1991); State v. Livingston , 282 S.C. 1, 6 , 317 S.E.2d 129, 132 (1984). “An insubstantial error not affecting the result of the trial is harmless where ‘guilt has been conclusively proven by competent evidence, such that no other rational conclusion can be reached.’” Adams , 354 S.C. at 380 , 580 S.E.2d at 795 (quoting State v. Bailey , 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989)).

2008Id.; Arnold v. State, 309 S.C. 157, 172 , 420 S.E.2d 834, 842 (1992); State v. Bailey, 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989).

2008Id.; Arnold v. State, 309 S.C. 157, 172 , 420 S.E.2d 834, 842 (1992); State v. Bailey, 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989).

2007Id. “An insubstantial error not affecting the result of the trial is harmless where guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.” State v. White , 372 S.C. 364, 386 , 642 S.E.2d 607, 618 (Ct. App. 2007).

2007Id. “An insubstantial error not affecting the result of the trial is harmless where guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.” State v. White , 372 S.C. 364, 386 , 642 S.E.2d 607, 618 (Ct. App. 2007).

2018See State v. Adams , 354 S.C. 361 , 380, 580 S.E.2d 785 , 795 (Ct. App. 2003) ("Error is harmless where it could not reasonably have affected the result of the trial."); id. at 381 , 580 S.E.2d at 795 ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result."); id. ("Thus, an insubstantial error not affecting the result of the trial is harmless where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.'" (quoting State v. Bailey , 298 S.C. 1 , 5, 377 S.E.2d 581 , 584 (1989) ) );

2018See State v. Adams , 354 S.C. 361 , 380, 580 S.E.2d 785 , 795 (Ct. App. 2003) ("Error is harmless where it could not reasonably have affected the result of the trial."); id. at 381 , 580 S.E.2d at 795 ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result."); id. ("Thus, an insubstantial error not affecting the result of the trial is harmless where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.'" (quoting State v. Bailey , 298 S.C. 1 , 5, 377 S.E.2d 581 , 584 (1989) ) );

2022See State v. Page, 378 S.C. 476, 483 , 663 S.E.2d 357, 360 (Ct. App. 2008) ("Error is harmless whe[n] it could not reasonably have affected the trial's outcome."); State v. Vick, 384 S.C. 189, 199 , 682 S.E.2d 275, 280 (Ct. App. 2009) ("An insubstantial error not affecting the result of the trial is harmless where guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.").

2022See State v. Page, 378 S.C. 476, 483 , 663 S.E.2d 357, 360 (Ct. App. 2008) ("Error is harmless whe[n] it could not reasonably have affected the trial's outcome."); State v. Vick, 384 S.C. 189, 199 , 682 S.E.2d 275, 280 (Ct. App. 2009) ("An insubstantial error not affecting the result of the trial is harmless where guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.").

2022See Pagan, 369 S.C. at 212 , 631 S.E.2d at 267 ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result."); State v. Byers, 392 S.C. 438, 447 , 710 S.E.2d 55, 60 (2011) ("Where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached,' an insubstantial error that does not affect the result of the trial is considered harmless." (quoting Pagan, 369 S.C. at 212 , 631 S.E.2d at 267 )); Smalls v. State, 422 S.C. 174, 191 , 810 S.E.2d 836, 845 (2018) (stating evidence of a defendant's guil

2022See Pagan, 369 S.C. at 212 , 631 S.E.2d at 267 ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result."); State v. Byers, 392 S.C. 438, 447 , 710 S.E.2d 55, 60 (2011) ("Where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached,' an insubstantial error that does not affect the result of the trial is considered harmless." (quoting Pagan, 369 S.C. at 212 , 631 S.E.2d at 267 )); Smalls v. State, 422 S.C. 174, 191 , 810 S.E.2d 836, 845 (2018) (stating evidence of a defendant's guil

2022DNA evidence demonstrating guilt"); Hutto v. State, 387 S.C. 244, 247, 249 , 692 S.E.2d 196, 197-98 (2010) (finding the victim's identification of the defendant and evidence of the defendant's DNA at the crime scene constituted overwhelming evidence the defendant was guilty of first-degree criminal sexual conduct, first-degree burglary, and armed robbery). 2.

2022DNA evidence demonstrating guilt"); Hutto v. State, 387 S.C. 244, 247, 249 , 692 S.E.2d 196, 197-98 (2010) (finding the victim's identification of the defendant and evidence of the defendant's DNA at the crime scene constituted overwhelming evidence the defendant was guilty of first-degree criminal sexual conduct, first-degree burglary, and armed robbery). 2.

2022See State v. Page, 378 S.C. 476, 483 , 663 S.E.2d 357, 360 (Ct. App. 2008) ("Error is harmless whe[n] it could not reasonably have affected the trial's outcome."); State v. Vick, 384 S.C. 189, 199 , 682 S.E.2d 275, 280 (Ct. App. 2009) ("An insubstantial error not affecting the result of the trial is harmless where guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.").

2022See State v. Page, 378 S.C. 476, 483 , 663 S.E.2d 357, 360 (Ct. App. 2008) ("Error is harmless whe[n] it could not reasonably have affected the trial's outcome."); State v. Vick, 384 S.C. 189, 199 , 682 S.E.2d 275, 280 (Ct. App. 2009) ("An insubstantial error not affecting the result of the trial is harmless where guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached.").

2020See State v. Brown, 424 S.C. 479, 493 , 818 S.E.2d 735, 743 (2018) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result." (quoting State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006))); id. ("Where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached,' an insubstantial error that does not affect the result of the trial is considered harmless." (quoting State v. Byers, 392 S.C. 438, 447 , 710 S.E.2d 55, 60 (2011))); id. ("Where a review of the entire record establis

2020See State v. Brown, 424 S.C. 479, 493 , 818 S.E.2d 735, 743 (2018) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result." (quoting State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006))); id. ("Where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached,' an insubstantial error that does not affect the result of the trial is considered harmless." (quoting State v. Byers, 392 S.C. 438, 447 , 710 S.E.2d 55, 60 (2011))); id. ("Where a review of the entire record establis

2020See State v. Brown, 424 S.C. 479, 493 , 818 S.E.2d 735, 743 (2018) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result." (quoting State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006))); id. ("Where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached,' an insubstantial error that does not affect the result of the trial is considered harmless." (quoting State v. Byers, 392 S.C. 438, 447 , 710 S.E.2d 55, 60 (2011))); id. ("Where a review of the entire record establis

2020See State v. Brown, 424 S.C. 479, 493 , 818 S.E.2d 735, 743 (2018) ("Generally, appellate courts will not set aside convictions due to insubstantial errors not affecting the result." (quoting State v. Pagan, 369 S.C. 201, 212 , 631 S.E.2d 262, 267 (2006))); id. ("Where 'guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached,' an insubstantial error that does not affect the result of the trial is considered harmless." (quoting State v. Byers, 392 S.C. 438, 447 , 710 S.E.2d 55, 60 (2011))); id. ("Where a review of the entire record establis

2013Whether the improper introduction of “evidence is harmless requires us to look at the other evidence admitted at trial to determine whether the defendant’s guilt is conclusively proven by competent evidence, such that no other rational conclusion could be reached.” State v. Brooks, 341 S.C. 57, 62-63 , 533 S.E.2d 325, 328 (2000) (internal quotation marks omitted); see also Lee-Grigg, 374 S.C. at 415 , 649 S.E.2d at 55 (finding an insubstantial error not affecting the result of the trial is harmless when guilt has been conclusively proven by competent evidence such that no other rational conclu

2013Whether the improper introduction of “evidence is harmless requires us to look at the other evidence admitted at trial to determine whether the defendant’s guilt is conclusively proven by competent evidence, such that no other rational conclusion could be reached.” State v. Brooks, 341 S.C. 57, 62-63 , 533 S.E.2d 325, 328 (2000) (internal quotation marks omitted); see also Lee-Grigg, 374 S.C. at 415 , 649 S.E.2d at 55 (finding an insubstantial error not affecting the result of the trial is harmless when guilt has been conclusively proven by competent evidence such that no other rational conclu

2013Whether the improper introduction of “evidence is harmless requires us to look at the other evidence admitted at trial to determine whether the defendant’s guilt is conclusively proven by competent evidence, such that no other rational conclusion could be reached.” State v. Brooks, 341 S.C. 57, 62-63 , 533 S.E.2d 325, 328 (2000) (internal quotation marks omitted); see also Lee-Grigg, 374 S.C. at 415 , 649 S.E.2d at 55 (finding an insubstantial error not affecting the result of the trial is harmless when guilt has been conclusively proven by competent evidence such that no other rational conclu

2013Whether the improper introduction of “evidence is harmless requires us to look at the other evidence admitted at trial to determine whether the defendant’s guilt is conclusively proven by competent evidence, such that no other rational conclusion could be reached.” State v. Brooks, 341 S.C. 57, 62-63 , 533 S.E.2d 325, 328 (2000) (internal quotation marks omitted); see also Lee-Grigg, 374 S.C. at 415 , 649 S.E.2d at 55 (finding an insubstantial error not affecting the result of the trial is harmless when guilt has been conclusively proven by competent evidence such that no other rational conclu

2012See State v. Bailey, 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989) (recognizing that an insubstantial error not affecting the result of the trial is harmless where “guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached”); State v. Knight, 258 S.C. 452, 454 , 189 S.E.2d 1, 2 (1972) (“[A] conviction will not be reversed for nonprejudicial error in the admission of evidence.”).

2012See State v. Bailey, 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989) (recognizing that an insubstantial error not affecting the result of the trial is harmless where “guilt has been conclusively proven by competent evidence such that no other rational conclusion can be reached”); State v. Knight, 258 S.C. 452, 454 , 189 S.E.2d 1, 2 (1972) (“[A] conviction will not be reversed for nonprejudicial error in the admission of evidence.”).

2012An insubstantial error is harmless when guilt is proven by competent evidence such that no other rational decision could be reached . . . ." (internal quotations and citations omitted)); Huggler v. State, 360 S.C. 627, 634-35 , 602 S.E.2d 753, 757 (2004) (holding the trial court did not err by allowing inadmissible hearsay testimony because the evidence of abuse was overwhelming).

2012An insubstantial error is harmless when guilt is proven by competent evidence such that no other rational decision could be reached . . . ." (internal quotations and citations omitted)); Huggler v. State, 360 S.C. 627, 634-35 , 602 S.E.2d 753, 757 (2004) (holding the trial court did not err by allowing inadmissible hearsay testimony because the evidence of abuse was overwhelming).

2011As to Issue 2: State v. Johnson , 338 S.C. 114, 124-25 , 525 S.E.2d 519, 524 (2000) (stating absent an abuse of discretion, an appellate court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test credibility or to show possible bias or self-interest in testifying).

2011As to Issue 2: State v. Johnson , 338 S.C. 114, 124-25 , 525 S.E.2d 519, 524 (2000) (stating absent an abuse of discretion, an appellate court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test credibility or to show possible bias or self-interest in testifying).

2008Code Ann. § 16-3-659.1 (1) (2003) (providing that specific instances of a victim’s own sexual conduct is not admissible in criminal sexual conduct prosecutions); State v. Grovenstein , 340 S.C. 210, 219 , 530 S.E.2d 406, 411 (Ct. App. 2000) (providing that evidence of a child witness’s prior sexual experience is “relevant to demonstrate that the defendant is not necessarily the source of the victim’s” knowledge of sexual matters).

2008Code Ann. § 16-3-659.1 (1) (2003) (providing that specific instances of a victim’s own sexual conduct is not admissible in criminal sexual conduct prosecutions); State v. Grovenstein , 340 S.C. 210, 219 , 530 S.E.2d 406, 411 (Ct. App. 2000) (providing that evidence of a child witness’s prior sexual experience is “relevant to demonstrate that the defendant is not necessarily the source of the victim’s” knowledge of sexual matters).

2007State v. Bailey, 298 S.C. 1 , 377 S.E.2d 581 (1989); Adams, 354 S.C. at 381 , 580 S.E.2d at 795 ; see also State v. Primus, 349 S.C. 576 , 564 S.E.2d 103 (2002) (holding assistant solicitor’s improper comment, during closing argument was harmless error, where evidence of guilt was overwhelming) overruled on other grounds; State v. Kelley, 319 S.C. 173 , 460 S.E.2d 368 (1995) (noting that when guilt is conclusively proven by competent evidence, such that no other rational conclusion could be reached, this court will not set aside conviction for insubstantial errors not affecting result).

2007State v. Bailey, 298 S.C. 1 , 377 S.E.2d 581 (1989); Adams, 354 S.C. at 381 , 580 S.E.2d at 795 ; see also State v. Primus, 349 S.C. 576 , 564 S.E.2d 103 (2002) (holding assistant solicitor’s improper comment, during closing argument was harmless error, where evidence of guilt was overwhelming) overruled on other grounds; State v. Kelley, 319 S.C. 173 , 460 S.E.2d 368 (1995) (noting that when guilt is conclusively proven by competent evidence, such that no other rational conclusion could be reached, this court will not set aside conviction for insubstantial errors not affecting result).

2004State v. Sherard , 303 S.C. 172, 176 , 399 S.E.2d 595, 597 (1991); State v. Livingston , 282 S.C. 1, 6 , 317 S.E.2d 129, 132 (1984). “An insubstantial error not affecting the result of the trial is harmless where ‘guilt has been conclusively proven by competent evidence, such that no other rational conclusion can be reached.’” Adams , 354 S.C. at 380 , 580 S.E.2d at 795 (quoting State v. Bailey , 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989)).

2004State v. Sherard , 303 S.C. 172, 176 , 399 S.E.2d 595, 597 (1991); State v. Livingston , 282 S.C. 1, 6 , 317 S.E.2d 129, 132 (1984). “An insubstantial error not affecting the result of the trial is harmless where ‘guilt has been conclusively proven by competent evidence, such that no other rational conclusion can be reached.’” Adams , 354 S.C. at 380 , 580 S.E.2d at 795 (quoting State v. Bailey , 298 S.C. 1, 5 , 377 S.E.2d 581, 584 (1989)).