State v. Commander, 396 S.C. 254

Victim Gervonya Goodwin was found mummified and partially decomposed in her home; Petitioner Christopher Commander had a romantic relationship with Victim and had access to her belongings.
Petitioner stole Victim’s purse, phone, and car; used Victim’s phone to text Victim’s family portraying her as alive.
Police recovered Victim’s personal items from Petitioner's hotel room and vehicle; Victim’s pregnancy and non-viable fetus were discovered.
Dr. Nichols, State pathologist, opined death by asphyxiation and homicide based on autopsy and circumstantial history; defense challenged as Rule 702 misuse.
Presley, jailhouse lawyer, testified Petitioner's statements to him included a possible accidental killing theory; defense sought accident/self-defense instructions.
Trial court admitted pathology testimony and refused to instruct on accident; jury convicted Petitioner of murder.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of expert testimony on manner of death	Commander argues Nichols’s ‘homicide’ opinion invades jury issue.	State contends expert testimony aids fact-finding under Rule 702.	Rule 702 admissible if not about defendant’s state of mind; error harmless.
Whether the trial court should have instructed on accident	Commander seeks accident instruction based on Presley testimony.	State argues no accident evidence supports instruction.	No accident evidence supported an instruction; affirmed denial.

State v. Bridges, 278 S.C. 447, 298 S.E.2d 212 (1982) (criminal trial conduct review limited to abuse of discretion)
State v. Baccus, 367 S.C. 41, 625 S.E.2d 216 (2006) (harmless error analysis factors applied)
State v. Douglas, 369 S.C. 424, 632 S.E.2d 845 (2006) (evidence-admission standard; harmless-error review)
State v. Mizzell, 349 S.C. 326, 563 S.E.2d 315 (2002) (harmless error factors for evidentiary ruling)
Green v. State, 351 S.C. 184, 569 S.E.2d 318 (2002) (expert testimony on legal conclusions exclusion)