State v. Heyward, 828 S.E.2d 592

In 2015, Denzel Heyward was charged with murder, attempted murder, armed robbery, and a firearms offense stemming from a robbery in which Kadeem Chambers was fatally shot; jury convicted Heyward of attempted murder, armed robbery, and the weapons charge but deadlocked on murder.
Heyward moved pretrial to exclude testimony that he had previously physically abused Quasantrina Rivers (the victim/witness and cooperating codefendant) as unduly prejudicial and propensity evidence.
The trial court initially barred direct testimony about past abuse but allowed the State to rehabilitate witness credibility if opened.
On cross-examination of Rivers’ mother (Sidearis Singleton), Heyward’s counsel asked about Rivers’ suicide attempts, mental health, and allegations of sexual assault against another person; after a bench conference, the State elicited testimony that Heyward had physically abused Rivers.
The jury convicted late at night after an Allen charge; Heyward was sentenced to consecutive terms totaling 65 years. The court of appeals affirmed, finding counsel had opened the door; the South Carolina Supreme Court granted certiorari.

Issue	Heyward's Argument	State's Argument	Held
Whether defense counsel opened the door to testimony that Heyward had previously abused Rivers	Counsel did not open the door; questioning about suicide, mental health, and sexual-assault accusations did not relate to past physical abuse	Counsel’s questions about Rivers’ condition and credibility opened the door; any error was harmless given other evidence	Court reversed: counsel did not open the door; admission of domestic-violence testimony was an abuse of discretion and not harmless; new trial ordered
Whether objection was preserved for review	The substance of the objection was apparent from pretrial record and in-court context	Objection not preserved because counsel failed to state grounds for record after bench conference	Court held the objection was preserved on the record based on context
Whether testimony admitted by open-door doctrine was proportional and confined	Admission exceeded scope of topics opened by defense questioning	Admission was permissible rebuttal to credibility issues raised	Court held the State’s response was not proportional; it improperly introduced propensity evidence
Harmless-error assessment	Admission was prejudicial because Rivers’ credibility was central and Singleton’s testimony corroborated her	Any error was harmless given the totality of evidence of guilt	Court held error was not harmless given the close case and centrality of Rivers’ testimony

State v. Page, 378 S.C. 476, 663 S.E.2d 357 (discretionary review of open-door rulings)
State v. Collins, 409 S.C. 524, 763 S.E.2d 22 (abuse of discretion standard explained)
State v. Young, 364 S.C. 476, 613 S.E.2d 386 (permitting rebuttal evidence when opponent introduces particular fact or transaction)
State v. Young, 378 S.C. 101, 661 S.E.2d 387 (caution against using open-door doctrine as a vehicle for propensity evidence)
Bowman v. State, 422 S.C. 19, 809 S.E.2d 232 (rebuttal testimony must be proportional and confined to topics opened)
State v. Byers, 392 S.C. 438, 710 S.E.2d 55 (objection preserved when grounds are apparent from context)
Allen v. United States, 164 U.S. 492 (authority for supplemental jury instruction when jurors report inability to agree)