South Carolina v. Broadnax
Annotate this CaseThe State appealed the court of appeals' decision to reverse respondent Christopher Broadnax's convictions for armed robbery and kidnapping, and remanding for a new trial. During his testimony, respondent denied any involvement in the robbery. However, Respondent's counsel elicited testimony regarding respondent's prior convictions for armed robbery. The State likewise questioned respondent about his prior convictions. The jury found respondent guilty of armed robbery and four counts of kidnapping, and the trial judge sentenced respondent to a mandatory minimum sentence of life imprisonment without the possibility of parole based on the prior armed robbery convictions. On appeal to the court of appeals, respondent argued, inter alia, that the trial court erred in admitting his prior armed robbery conviction for impeachment purposes. The court of appeals reversed and remanded the case to the trial court for a new trial. Specifically, the court of appeals found: (1) respondent's prior armed robbery convictions, without more, did not constitute crimes of dishonesty, and therefore, the trial court should have conducted a balancing test prior to admitting testimony regarding Respondent's prior armed robbery convictions; and (2) such error was not harmless beyond a reasonable doubt. Upon review, the Supreme Court disagreed with the State's argument that the court of appeals erred in reversing the trial court because armed robbery was a "crime of dishonesty or false statement" such that it is automatically admissible under Rule 609(a)(2), SCRE. The Court agreed, however, with the State's contention that the error in admitting the prior armed robbery convictions was harmless beyond a reasonable doubt. The Supreme Court found other evidence implicating respondent in those crimes was overwhelming. The Supreme Court affirmed in part, reversed in part, and remanded for further proceedings.
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