South Carolina v. Robinson

Stephon Robinson was convicted of first-degree burglary and possession of a weapon during the commission of a violent crime. Robinson appealed, and the court of appeals remanded the matter to the trial court to conduct an on-the-record balancing test regarding the admissibility of certain prior convictions the State used to impeach Robinson's credibility pursuant to Rule 609(a)(1) of the South Carolina Rules of Evidence. After the remand hearing, the trial court ruled Robinson's prior convictions were properly admitted; consequently, the burglary and weapon convictions remained in place. Robinson appealed again, and the court of appeals issued an unpublished opinion holding that although the trial court erred in applying two of the five factors the South Carolina Supreme Court set forth in South Carolina v. Colf, 535 S.E.2d 246 (2000), any error in the admission of Robinson's prior convictions for impeachment was harmless. The Supreme Court granted cross-petitions for writs of certiorari to review the court of appeals' decision. The Court affirmed the court of appeals as modified: the court of appeals reached the correct result by affirming Robinson's convictions; however, its analysis of the admissibility of the prior convictions was erroneous. View "South Carolina v. Robinson" on Justia Law