State v. Byers, 392 S.C. 438

On June 10, 2005, the Fort Rock Bingo Hall in Rock Hill was robbed at gunpoint around 10:10 p.m.
Petitioner Najjar De'Breece Byers was a passenger in a blue Nissan Altima stopped in Charlotte about 11:15 p.m. the same night.
Crisco and Thompson pleaded guilty to the Rock Hill armed robbery; Crisco testified inconsistently about who was in the car.
Crisco testified he relied on a discovery motion identifying Petitioner, prompting defense to move to strike the testimony as hearsay; the circuit court denied.
Petitioner presented alibi witnesses (mother, father, ex-girlfriend); fingerprints did not link Petitioner to the crime; Petitioner was convicted of armed robbery and conspiracy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the hearsay objection properly preserved?	Byers preserved error with a timely, specific motion to strike Crisco's testimony.	Preservation required an immediate objection; motion to strike alone was insufficient.	Objection preserved; admission of hearsay was error under Rule 801(c).
Was the admission of Crisco's hearsay testimony harmless error?	Crisco's testimony was crucial to prove Byers was in the vehicle during the robbery.	Other evidence could support guilt even without Crisco's testimony.	Admission was prejudicial; conviction reversed.

State v. Williams, 386 S.C. 503 (2010) (abuse of discretion standard for evidentiary rulings)
State v. McDonald, 343 S.C. 319 (2000) (abuse of discretion when ruling on evidence)
Vaught v. A.O. Hardee & Sons, Inc., 366 S.C. 475 (2005) (prejudice required to reverse evidentiary error)
State v. Saltz, 346 S.C. 114 (2001) (timeliness and specificity of objections to preserve error)
State v. Rice, 375 S.C. 302 (2007) (grounds for objection must be apparent from context)
Wilder Corp. v. Wilke, 330 S.C. 71 (1998) (specificity and preservation of objections)
State v. Simpson, 325 S.C. 37 (1996) (contemporaneous objection principle)
State v. Torrence, 305 S.C. 45 (1991) (objection timing and preservation)
State v. Stahlnecker, 386 S.C. 609 (2010) (contextual assessment of objection specificity)
State v. Reeves, 301 S.C. 191 (1990) (harmless error evaluation)
State v. Pagan, 369 S.C. 201 (2006) (harmless error in sufficiency of evidence context)