South Carolina v. Brown

A restaurant in Goose Creek, South Carolina, was robbed by two males wearing ski masks and gloves while carrying a gun and knife, around midnight on Christmas Eve. During the robbery, an employee was shot by one of the robbers. As a result of law enforcement's investigation, including a traced scent trail, DNA evidence found on a ski mask and gun, an executed search warrant, and a tip that Petitioner Donte Brown confessed to committing the crime with Christopher Wilson, Petitioner and Wilson were arrested and charged with robbery, as well as other crimes stemming from the incident. In addition, during the course of their investigation, law enforcement discovered that Wilson was wearing a GPS ankle monitor at the time of the robbery. Wilson's GPS records reflected that he was at the restaurant during the robbery. Wilson pled guilty prior to Petitioner's trial. At Petitioner's trial, the State connected Wilson to Petitioner, through Wilson's GPS records and otherwise. This appeal was centered on Petitioner's challenge that the State failed to authenticate Wilson's GPS records. The South Carolina Supreme Court held that the State failed to properly authenticate the GPS records, and it was error to admit this evidence. Nevertheless, due to the overwhelming evidence of guilt, the Court affirmed the court of appeals in result because this error was harmless beyond a reasonable doubt. View "South Carolina v. Brown" on Justia Law