Walker factors in South Carolina

2025See United States v. Walker, 772 F.2d 1172 (5th Cir. 1985) (utilizing a set of factors to determine if the trial court abused its discretion in denying a defendant's motion to reopen the evidence to allow his testimony when the defendant made the motion after he rested but before closing arguments or jury instructions were given); see also United States v. Orozco, 764 F.3d 997, 1001 (9th Cir. 2014) (using the Walker factors "to determine whether a district court abused its discretion in denying a motion to reopen to allow a defendant to testify"); United States v. Byrd, 403 F.3d 1278, 1283 (11

2025See United States v. Walker, 772 F.2d 1172 (5th Cir. 1985) (utilizing a set of factors to determine if the trial court abused its discretion in denying a defendant's motion to reopen the evidence to allow his testimony when the defendant made the motion after he rested but before closing arguments or jury instructions were given); see also United States v. Orozco, 764 F.3d 997, 1001 (9th Cir. 2014) (using the Walker factors "to determine whether a district court abused its discretion in denying a motion to reopen to allow a defendant to testify"); United States v. Byrd, 403 F.3d 1278, 1283 (11

2025Cir. 2000) (applying the Walker factors to the district court's decision not to reopen the evidence to allow the defendant to testify); People v. Martin, 2014 COA 112, ¶ 37 , 338 P.3d 1106, 1116 ("We are persuaded that [the Walker] factors articulate part of an appropriate test for Colorado trial courts to employ when exercising their discretion to determine whether to allow revocation of the waiver and reopening of the evidence for a defendant to testify."); Bloomquist v. State, 832 P.2d 177, 180 (Alaska Ct. App. 1992) ("Where the defendant moves to reopen his case to testify on his own behal

2025Cir. 2000) (applying the Walker factors to the district court's decision not to reopen the evidence to allow the defendant to testify); People v. Martin, 2014 COA 112, ¶ 37 , 338 P.3d 1106, 1116 ("We are persuaded that [the Walker] factors articulate part of an appropriate test for Colorado trial courts to employ when exercising their discretion to determine whether to allow revocation of the waiver and reopening of the evidence for a defendant to testify."); Bloomquist v. State, 832 P.2d 177, 180 (Alaska Ct. App. 1992) ("Where the defendant moves to reopen his case to testify on his own behal

2025Cir. 2000) (applying the Walker factors to the district court's decision not to reopen the evidence to allow the defendant to testify); People v. Martin, 2014 COA 112, ¶ 37 , 338 P.3d 1106, 1116 ("We are persuaded that [the Walker] factors articulate part of an appropriate test for Colorado trial courts to employ when exercising their discretion to determine whether to allow revocation of the waiver and reopening of the evidence for a defendant to testify."); Bloomquist v. State, 832 P.2d 177, 180 (Alaska Ct. App. 1992) ("Where the defendant moves to reopen his case to testify on his own behal

2025Cir. 2000) (applying the Walker factors to the district court's decision not to reopen the evidence to allow the defendant to testify); People v. Martin, 2014 COA 112, ¶ 37 , 338 P.3d 1106, 1116 ("We are persuaded that [the Walker] factors articulate part of an appropriate test for Colorado trial courts to employ when exercising their discretion to determine whether to allow revocation of the waiver and reopening of the evidence for a defendant to testify."); Bloomquist v. State, 832 P.2d 177, 180 (Alaska Ct. App. 1992) ("Where the defendant moves to reopen his case to testify on his own behal

2025See United States v. Walker, 772 F.2d 1172 (5th Cir. 1985) (utilizing a set of factors to determine if the trial court abused its discretion in denying a defendant's motion to reopen the evidence to allow his testimony when the defendant made the motion after he rested but before closing arguments or jury instructions were given); see also United States v. Orozco, 764 F.3d 997, 1001 (9th Cir. 2014) (using the Walker factors "to determine whether a district court abused its discretion in denying a motion to reopen to allow a defendant to testify"); United States v. Byrd, 403 F.3d 1278, 1283 (11

2025See United States v. Walker, 772 F.2d 1172 (5th Cir. 1985) (utilizing a set of factors to determine if the trial court abused its discretion in denying a defendant's motion to reopen the evidence to allow his testimony when the defendant made the motion after he rested but before closing arguments or jury instructions were given); see also United States v. Orozco, 764 F.3d 997, 1001 (9th Cir. 2014) (using the Walker factors "to determine whether a district court abused its discretion in denying a motion to reopen to allow a defendant to testify"); United States v. Byrd, 403 F.3d 1278, 1283 (11

2025The Eleventh Circuit also looked at how the First Circuit had applied the Walker factors in Peterson, 233 F.3d 101 .

2025The Eleventh Circuit also looked at how the First Circuit had applied the Walker factors in Peterson, 233 F.3d 101 .

2025See United States v. Walker, 772 F.2d 1172 (5th Cir. 1985) (utilizing a set of factors to determine if the trial court abused its discretion in denying a defendant's motion to reopen the evidence to allow his testimony when the defendant made the motion after he rested but before closing arguments or jury instructions were given); see also United States v. Orozco, 764 F.3d 997, 1001 (9th Cir. 2014) (using the Walker factors "to determine whether a district court abused its discretion in denying a motion to reopen to allow a defendant to testify"); United States v. Byrd, 403 F.3d 1278, 1283 (11

2025See United States v. Walker, 772 F.2d 1172 (5th Cir. 1985) (utilizing a set of factors to determine if the trial court abused its discretion in denying a defendant's motion to reopen the evidence to allow his testimony when the defendant made the motion after he rested but before closing arguments or jury instructions were given); see also United States v. Orozco, 764 F.3d 997, 1001 (9th Cir. 2014) (using the Walker factors "to determine whether a district court abused its discretion in denying a motion to reopen to allow a defendant to testify"); United States v. Byrd, 403 F.3d 1278, 1283 (11

2022See 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 [circuit] court, and [an appellate court] will not disturb the [circuit] court's decision absent an abuse of discretion."); id. at 167 , 672 S.E.2d at 565 ("The deferential standard of review constrains [an appellate court] to affirm the [circuit] court if reasonably supported by the evidence."); State v. Harris, 391 S.C. 539, 545 , 706 S.E.2d 526, 529 (Ct. App. 2011) ("The credibility of newly-discovered evidence is for the [circuit] court to

2022See 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 [circuit] court, and [an appellate court] will not disturb the [circuit] court's decision absent an abuse of discretion."); id. at 167 , 672 S.E.2d at 565 ("The deferential standard of review constrains [an appellate court] to affirm the [circuit] court if reasonably supported by the evidence."); State v. Harris, 391 S.C. 539, 545 , 706 S.E.2d 526, 529 (Ct. App. 2011) ("The credibility of newly-discovered evidence is for the [circuit] court to

2022See 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 [circuit] court, and [an appellate court] will not disturb the [circuit] court's decision absent an abuse of discretion."); id. at 167 , 672 S.E.2d at 565 ("The deferential standard of review constrains [an appellate court] to affirm the [circuit] court if reasonably supported by the evidence."); State v. Harris, 391 S.C. 539, 545 , 706 S.E.2d 526, 529 (Ct. App. 2011) ("The credibility of newly-discovered evidence is for the [circuit] court to

2022See 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 [circuit] court, and [an appellate court] will not disturb the [circuit] court's decision absent an abuse of discretion."); id. at 167 , 672 S.E.2d at 565 ("The deferential standard of review constrains [an appellate court] to affirm the [circuit] court if reasonably supported by the evidence."); State v. Harris, 391 S.C. 539, 545 , 706 S.E.2d 526, 529 (Ct. App. 2011) ("The credibility of newly-discovered evidence is for the [circuit] court to

2019Evidence to prove personal knowledge may, but need not, consist of the witness' own testimony."); McPeters v. Yeargin Const. Co., 290 S.C. 327, 332 , 350 S.E.2d 208, 211 (Ct. App. 1986) ("A motion to strike testimony after it has been admitted without objection is addressed to the sound discretion of the [master].").3 AFFIRMED.4 HUFF, WILLIAMS, and MCDONALD, JJ., concur. 2 To the extent Walker argues his lack of notice of mediation violated his due process rights, we find this issue was not preserved for appellate review because it was not raised to or ruled on by the master.

2019Evidence to prove personal knowledge may, but need not, consist of the witness' own testimony."); McPeters v. Yeargin Const. Co., 290 S.C. 327, 332 , 350 S.E.2d 208, 211 (Ct. App. 1986) ("A motion to strike testimony after it has been admitted without objection is addressed to the sound discretion of the [master].").3 AFFIRMED.4 HUFF, WILLIAMS, and MCDONALD, JJ., concur. 2 To the extent Walker argues his lack of notice of mediation violated his due process rights, we find this issue was not preserved for appellate review because it was not raised to or ruled on by the master.

2017As to whether the trial court abused its discretion by denying Walker's motion for a continuance: State v. Meggett, 398 S.C. 516, 523 , 728 S.E.2d 492, 496 (Ct. App. 2012) ("The denial of a motion for a continuance is within the sound discretion of the trial court and will not be disturbed absent a showing of an abuse of discretion resulting in prejudice."); id. at 523 , 728 S.E.2d at 496 ("When a motion for a continuance is based upon the contention that counsel for the defendant has not had time to prepare his case its denial by the trial court has rarely been disturbed on appeal." (quoting

2017As to whether the trial court abused its discretion by denying Walker's motion for a continuance: State v. Meggett, 398 S.C. 516, 523 , 728 S.E.2d 492, 496 (Ct. App. 2012) ("The denial of a motion for a continuance is within the sound discretion of the trial court and will not be disturbed absent a showing of an abuse of discretion resulting in prejudice."); id. at 523 , 728 S.E.2d at 496 ("When a motion for a continuance is based upon the contention that counsel for the defendant has not had time to prepare his case its denial by the trial court has rarely been disturbed on appeal." (quoting

2017As to whether the trial court abused its discretion by denying Walker's motion for a continuance: State v. Meggett, 398 S.C. 516, 523 , 728 S.E.2d 492, 496 (Ct. App. 2012) ("The denial of a motion for a continuance is within the sound discretion of the trial court and will not be disturbed absent a showing of an abuse of discretion resulting in prejudice."); id. at 523 , 728 S.E.2d at 496 ("When a motion for a continuance is based upon the contention that counsel for the defendant has not had time to prepare his case its denial by the trial court has rarely been disturbed on appeal." (quoting

2017As to whether the trial court abused its discretion by denying Walker's motion for a continuance: State v. Meggett, 398 S.C. 516, 523 , 728 S.E.2d 492, 496 (Ct. App. 2012) ("The denial of a motion for a continuance is within the sound discretion of the trial court and will not be disturbed absent a showing of an abuse of discretion resulting in prejudice."); id. at 523 , 728 S.E.2d at 496 ("When a motion for a continuance is based upon the contention that counsel for the defendant has not had time to prepare his case its denial by the trial court has rarely been disturbed on appeal." (quoting

2010We affirm[1] pursuant to Rule 220(b), SCACR, and the following authorities: Rule 201(b), SCACR ("Only a party aggrieved by an order, judgment, sentence or decision may appeal."); Beaufort Realty Co., Inc. v. Beaufort County , 346 S.C. 298, 301 , 551 S.E.2d 588, 589-90 (Ct. App. 2001) ("A party cannot appeal from a decision which does not affect his or her interest, however erroneous and prejudicial it may be to some other person's rights and interests."); Id. at 301, 551 S.E.2d at 589 ("The word 'aggrieved' refers to a substantial grievance, a denial of some personal or property right, or the

2010We affirm[1] pursuant to Rule 220(b), SCACR, and the following authorities: Rule 201(b), SCACR ("Only a party aggrieved by an order, judgment, sentence or decision may appeal."); Beaufort Realty Co., Inc. v. Beaufort County , 346 S.C. 298, 301 , 551 S.E.2d 588, 589-90 (Ct. App. 2001) ("A party cannot appeal from a decision which does not affect his or her interest, however erroneous and prejudicial it may be to some other person's rights and interests."); Id. at 301, 551 S.E.2d at 589 ("The word 'aggrieved' refers to a substantial grievance, a denial of some personal or property right, or the

1992See State v. Mathis, 287 S.C. 589 , 340 S.E. (2d) 538 (1986) (motion for directed verdict of acquittal must be refused and case sent to jury if there is any evidence reasonably tending to prove the guilt of the accused).

1992See State v. Mathis, 287 S.C. 589 , 340 S.E. (2d) 538 (1986) (motion for directed verdict of acquittal must be refused and case sent to jury if there is any evidence reasonably tending to prove the guilt of the accused).