witness test in South Carolina

2024An appellate court "will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion." State v. Hawes, 423 S.C. 118, 135 , 813 S.E.2d 513, 522 (Ct. App. 2018) (quoting State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012).

2024An appellate court "will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion." State v. Hawes, 423 S.C. 118, 135 , 813 S.E.2d 513, 522 (Ct. App. 2018) (quoting State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012).

2018As to issue seven: State v. Johnson, 338 S.C. 114, 124-25 , 525 S.E.2d 519, 524 (2000) ("An appellate court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Aleksey, 343 S.C. 20, 34 , 538 S.E.2d 248, 255 (2000) ("[T]rial [courts] retain wide latitude insofar as the Confrontation Clause is concerned to impose reasonable limits on such cross-examination based on concerns about, among other 1 We decide this case w

2018As to issue seven: State v. Johnson, 338 S.C. 114, 124-25 , 525 S.E.2d 519, 524 (2000) ("An appellate court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Aleksey, 343 S.C. 20, 34 , 538 S.E.2d 248, 255 (2000) ("[T]rial [courts] retain wide latitude insofar as the Confrontation Clause is concerned to impose reasonable limits on such cross-examination based on concerns about, among other 1 We decide this case w

2001Cf. State v. Lynn, 277 S.C. 222 , 284 S.E.2d 786 (1981) (a trial court’s ruling concerning the scope of cross-examination of a witness to test his credibility should not be disturbed on appeal absent a manifest abuse of discretion).

2001Cf. State v. Lynn, 277 S.C. 222 , 284 S.E.2d 786 (1981) (a trial court’s ruling concerning the scope of cross-examination of a witness to test his credibility should not be disturbed on appeal absent a manifest abuse of discretion).

2025See State v. Smith, 315 S.C. 547, 551 , 446 S.E.2d 411, 413 (1994) (providing that an appellate court "will not disturb on appeal a trial court's ruling concerning the scope of cross-examination of a witness to test his credibility absent a manifest abuse of discretion"); State v. Pagan, 369 S.C. 201, 208 , 631 S.E.2d 262, 265 (2006) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law."); Rule 403, SCRE ("Although relevant, evidence may be excluded if its probative value is substantially outweighed by the

2025See State v. Smith, 315 S.C. 547, 551 , 446 S.E.2d 411, 413 (1994) (providing that an appellate court "will not disturb on appeal a trial court's ruling concerning the scope of cross-examination of a witness to test his credibility absent a manifest abuse of discretion"); State v. Pagan, 369 S.C. 201, 208 , 631 S.E.2d 262, 265 (2006) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law."); Rule 403, SCRE ("Although relevant, evidence may be excluded if its probative value is substantially outweighed by the

2023See State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("This Court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Douglas, 369 S.C. 424, 429-30 , 632 S.E.2d 845, 848 (2006) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law."); Gracely, 399 S.C. at 372 , 731 S.E.2d at 885 ("The Confrontation Clause guarant

2018As to issue seven: State v. Johnson, 338 S.C. 114, 124-25 , 525 S.E.2d 519, 524 (2000) ("An appellate court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Aleksey, 343 S.C. 20, 34 , 538 S.E.2d 248, 255 (2000) ("[T]rial [courts] retain wide latitude insofar as the Confrontation Clause is concerned to impose reasonable limits on such cross-examination based on concerns about, among other 1 We decide this case w

2019"An appellate court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion." Yoho v. Thompson , 345 S.C. 361 , 365, 548 S.E.2d 584 , 585 (2001). **191 "An abuse of discretion occurs when the trial court's ruling is based on an error of law or, when grounded in factual conclusions, is without evidentiary support." Clark v. Cantrell , 339 S.C. 369 , 389, 529 S.E.2d 528 , 539 (2000).

2019"An appellate court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion." Yoho v. Thompson , 345 S.C. 361 , 365, 548 S.E.2d 584 , 585 (2001). **191 "An abuse of discretion occurs when the trial court's ruling is based on an error of law or, when grounded in factual conclusions, is without evidentiary support." Clark v. Cantrell , 339 S.C. 369 , 389, 529 S.E.2d 528 , 539 (2000).

2023"This [c]ourt will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion." State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012); see also State v. Perez, 423 S.C. 491, 496-97 , 816 S.E.2d 550, 553 (2018) ("An abuse of discretion occurs when the trial court's ruling is based on an error of law or is based on findings of fact that are without evidentiary support.").

2023"This [c]ourt will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion." State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012); see also State v. Perez, 423 S.C. 491, 496-97 , 816 S.E.2d 550, 553 (2018) ("An abuse of discretion occurs when the trial court's ruling is based on an error of law or is based on findings of fact that are without evidentiary support.").

2020We affirm pursuant to Rule 220(b), SCACR and the following authorities: State v. Mizzell, 349 S.C. 326, 331 , 563 S.E.2d 315, 317 (2002) ("The trial [court] retains discretion to impose reasonable limits on the scope of cross-examination."); id. ("Before a trial [court] may limit a criminal defendant's right to engage in cross-examination to show bias on the part of the witness, the record must clearly show the cross-examination is inappropriate."); State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("[The appellate court] will not disturb a trial court's ruling concerning the sc

2020We affirm pursuant to Rule 220(b), SCACR and the following authorities: State v. Mizzell, 349 S.C. 326, 331 , 563 S.E.2d 315, 317 (2002) ("The trial [court] retains discretion to impose reasonable limits on the scope of cross-examination."); id. ("Before a trial [court] may limit a criminal defendant's right to engage in cross-examination to show bias on the part of the witness, the record must clearly show the cross-examination is inappropriate."); State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("[The appellate court] will not disturb a trial court's ruling concerning the sc

2018As to issue seven: State v. Johnson, 338 S.C. 114, 124-25 , 525 S.E.2d 519, 524 (2000) ("An appellate court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Aleksey, 343 S.C. 20, 34 , 538 S.E.2d 248, 255 (2000) ("[T]rial [courts] retain wide latitude insofar as the Confrontation Clause is concerned to impose reasonable limits on such cross-examination based on concerns about, among other 1 We decide this case w

2018As to issue seven: State v. Johnson, 338 S.C. 114, 124-25 , 525 S.E.2d 519, 524 (2000) ("An appellate court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Aleksey, 343 S.C. 20, 34 , 538 S.E.2d 248, 255 (2000) ("[T]rial [courts] retain wide latitude insofar as the Confrontation Clause is concerned to impose reasonable limits on such cross-examination based on concerns about, among other 1 We decide this case w

2018Gilliland v. Doe , 357 S.C. 197 , 199, 592 S.E.2d 626 , 627 (2004) (noting the witness requirement is a "safeguard" enacted to prevent fraudulent claims); Wausau Underwriters Ins.

2018Gilliland v. Doe , 357 S.C. 197 , 199, 592 S.E.2d 626 , 627 (2004) (noting the witness requirement is a "safeguard" enacted to prevent fraudulent claims); Wausau Underwriters Ins.

1999In doing so the witness may be asked questions in reference to irrelevant matter, or in reference to prior statements contradictory of his testimony, or in reference to statements as to relevant matter not contradictory of his testimony.’ McMillan v. Ridges, 229 S.C. 76, 80-81 , 91 S.E.2d 883, 885 (1956) (citation omitted).

1999In doing so the witness may be asked questions in reference to irrelevant matter, or in reference to prior statements contradictory of his testimony, or in reference to statements as to relevant matter not contradictory of his testimony.’ McMillan v. Ridges, 229 S.C. 76, 80-81 , 91 S.E.2d 883, 885 (1956) (citation omitted).

2025See State v. Smith, 315 S.C. 547, 551 , 446 S.E.2d 411, 413 (1994) (providing that an appellate court "will not disturb on appeal a trial court's ruling concerning the scope of cross-examination of a witness to test his credibility absent a manifest abuse of discretion"); State v. Pagan, 369 S.C. 201, 208 , 631 S.E.2d 262, 265 (2006) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law."); Rule 403, SCRE ("Although relevant, evidence may be excluded if its probative value is substantially outweighed by the

2025See State v. Smith, 315 S.C. 547, 551 , 446 S.E.2d 411, 413 (1994) (providing that an appellate court "will not disturb on appeal a trial court's ruling concerning the scope of cross-examination of a witness to test his credibility absent a manifest abuse of discretion"); State v. Pagan, 369 S.C. 201, 208 , 631 S.E.2d 262, 265 (2006) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law."); Rule 403, SCRE ("Although relevant, evidence may be excluded if its probative value is substantially outweighed by the

2024An appellate court "will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion." State v. Hawes, 423 S.C. 118, 135 , 813 S.E.2d 513, 522 (Ct. App. 2018) (quoting State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012).

2024An appellate court "will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion." State v. Hawes, 423 S.C. 118, 135 , 813 S.E.2d 513, 522 (Ct. App. 2018) (quoting State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012).

2024Similarly, "[w]hether a person opens the door to the admission of otherwise inadmissible evidence during the course of a trial is addressed to the sound discretion of the trial judge." State v. Page, 378 S.C. 476, 483 , 663 S.E.2d 357, 360 (Ct. App. 2008).

2024Similarly, "[w]hether a person opens the door to the admission of otherwise inadmissible evidence during the course of a trial is addressed to the sound discretion of the trial judge." State v. Page, 378 S.C. 476, 483 , 663 S.E.2d 357, 360 (Ct. App. 2008).

2023See State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("This Court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Douglas, 369 S.C. 424, 429-30 , 632 S.E.2d 845, 848 (2006) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law."); Gracely, 399 S.C. at 372 , 731 S.E.2d at 885 ("The Confrontation Clause guarant

2023See State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("This Court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Douglas, 369 S.C. 424, 429-30 , 632 S.E.2d 845, 848 (2006) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law."); Gracely, 399 S.C. at 372 , 731 S.E.2d at 885 ("The Confrontation Clause guarant

2023See State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("This Court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Douglas, 369 S.C. 424, 429-30 , 632 S.E.2d 845, 848 (2006) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law."); Gracely, 399 S.C. at 372 , 731 S.E.2d at 885 ("The Confrontation Clause guarant

2023See State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("This Court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Douglas, 369 S.C. 424, 429-30 , 632 S.E.2d 845, 848 (2006) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law."); Gracely, 399 S.C. at 372 , 731 S.E.2d at 885 ("The Confrontation Clause guarant

2023See State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("This Court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Douglas, 369 S.C. 424, 429-30 , 632 S.E.2d 845, 848 (2006) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law."); Gracely, 399 S.C. at 372 , 731 S.E.2d at 885 ("The Confrontation Clause guarant

2023See State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("This Court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Douglas, 369 S.C. 424, 429-30 , 632 S.E.2d 845, 848 (2006) ("An abuse of discretion occurs when the conclusions of the trial court either lack evidentiary support or are controlled by an error of law."); Gracely, 399 S.C. at 372 , 731 S.E.2d at 885 ("The Confrontation Clause guarant

2019"To warrant reversal based on the admission or exclusion of evidence, the appellant must prove both the error of the ruling and the resulting prejudice, i.e., that there is a reasonable probability the jury's verdict was influenced by the challenged evidence or the lack thereof." State v. Commander , 396 S.C. 254 , 263, 721 S.E.2d 413 , 418 (2011) ; State v. Colf , 337 S.C. 622 , 625, 525 S.E.2d 246 , 247-48 (2000) ("The scope of cross-examination is within the discretion of the trial judge, whose decision will not be reversed on appeal absent a showing of prejudice.").

2019"To warrant reversal based on the admission or exclusion of evidence, the appellant must prove both the error of the ruling and the resulting prejudice, i.e., that there is a reasonable probability the jury's verdict was influenced by the challenged evidence or the lack thereof." State v. Commander , 396 S.C. 254 , 263, 721 S.E.2d 413 , 418 (2011) ; State v. Colf , 337 S.C. 622 , 625, 525 S.E.2d 246 , 247-48 (2000) ("The scope of cross-examination is within the discretion of the trial judge, whose decision will not be reversed on appeal absent a showing of prejudice.").

2018As to issue seven: State v. Johnson, 338 S.C. 114, 124-25 , 525 S.E.2d 519, 524 (2000) ("An appellate court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Aleksey, 343 S.C. 20, 34 , 538 S.E.2d 248, 255 (2000) ("[T]rial [courts] retain wide latitude insofar as the Confrontation Clause is concerned to impose reasonable limits on such cross-examination based on concerns about, among other 1 We decide this case w

2018As to issue seven: State v. Johnson, 338 S.C. 114, 124-25 , 525 S.E.2d 519, 524 (2000) ("An appellate court will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Aleksey, 343 S.C. 20, 34 , 538 S.E.2d 248, 255 (2000) ("[T]rial [courts] retain wide latitude insofar as the Confrontation Clause is concerned to impose reasonable limits on such cross-examination based on concerns about, among other 1 We decide this case w

2018Co. v. Howser , 309 S.C. 269 , 275, 422 S.E.2d 106 , 109 (1992) ("The purpose of the second condition in this statute is to assure adequate proof the accident involved a second unknown vehicle.").

2018Co. v. Howser , 309 S.C. 269 , 275, 422 S.E.2d 106 , 109 (1992) ("The purpose of the second condition in this statute is to assure adequate proof the accident involved a second unknown vehicle.").

2015We affirm pursuant to Rule 220(b), SCACR, and the following authorities: State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("[Appellate courts] will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Mizzell, 349 S.C. 326, 331 , 563 S.E.2d 315, 317 (2002) ("A defendant has the right to cross-examine a witness concerning bias under the Confrontation Clause."); State v. Pradubsri, 403 S.C. 270 , 276–77, 7

2015We affirm pursuant to Rule 220(b), SCACR, and the following authorities: State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("[Appellate courts] will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Mizzell, 349 S.C. 326, 331 , 563 S.E.2d 315, 317 (2002) ("A defendant has the right to cross-examine a witness concerning bias under the Confrontation Clause."); State v. Pradubsri, 403 S.C. 270 , 276–77, 7

2015We affirm pursuant to Rule 220(b), SCACR, and the following authorities: State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("[Appellate courts] will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Mizzell, 349 S.C. 326, 331 , 563 S.E.2d 315, 317 (2002) ("A defendant has the right to cross-examine a witness concerning bias under the Confrontation Clause."); State v. Pradubsri, 403 S.C. 270 , 276–77, 7

2015We affirm pursuant to Rule 220(b), SCACR, and the following authorities: State v. Gracely, 399 S.C. 363, 371 , 731 S.E.2d 880, 884 (2012) ("[Appellate courts] will not disturb a trial court's ruling concerning the scope of cross-examination of a witness to test his or her credibility, or to show possible bias or self-interest in testifying, absent a manifest abuse of discretion."); State v. Mizzell, 349 S.C. 326, 331 , 563 S.E.2d 315, 317 (2002) ("A defendant has the right to cross-examine a witness concerning bias under the Confrontation Clause."); State v. Pradubsri, 403 S.C. 270 , 276–77, 7

2013It is for such reasons that considerable latitude is allowed in the cross-examination of a witness to test the accuracy of his memory, his bias, prejudice, interest, or credibility; “a witness may be asked questions ... in reference to prior statements contradictory of [his] testimony, or in reference to statements concerning relevant matter not contradictory of testimony.” State v. Jenkins, 322 S.C. 360, 364 , 474 S.E.2d 812, 814 (Ct.App.1996) (emphasis added).

2013It is for such reasons that considerable latitude is allowed in the cross-examination of a witness to test the accuracy of his memory, his bias, prejudice, interest, or credibility; “a witness may be asked questions ... in reference to prior statements contradictory of [his] testimony, or in reference to statements concerning relevant matter not contradictory of testimony.” State v. Jenkins, 322 S.C. 360, 364 , 474 S.E.2d 812, 814 (Ct.App.1996) (emphasis added).