State v. Williams, 844 S.E.2d 57

After a late-night confrontation in a bar parking lot, Terry Williams shot and killed Larry Moore and wounded Reva McFadden; Williams claimed self-defense. He was indicted for murder, ABHAN, and a weapons charge; a jury convicted him of voluntary manslaughter (lesser-included), ABHAN, and the weapons offense.
At a pretrial immunity hearing McFadden (the surviving victim/witness) admitted two prior domestic incidents in which Williams allegedly brandished firearms and she called police.
At trial McFadden testified for the State that Williams appeared scared and that he "never been in a confrontation in his whole entire life with anyone"; the prosecution sought to impeach that assertion on redirect.
The trial court permitted the State to elicit detailed testimony about the two prior incidents (including that Williams displayed a gun and police were called) under Rule 404(a)(1) and Rule 607, over Williams' objection.
The court of appeals affirmed; the South Carolina Supreme Court granted certiorari, held the trial court erred by admitting the prejudicial details (beyond impeachment scope), found the error not harmless, reversed, and remanded for a new trial.

Issue	State's Argument	Williams' Argument	Held
Whether defense "opened the door" so Rule 404(a)(1) permitted detailed rebuttal character evidence	Defense questions invited rebuttal that Williams was not peaceful	Defense did not open the door at trial; prior immunity hearing issues aside	Trial court erred to rely on Rule 404(a)(1); defense did not open the door at trial
Whether the prosecution could impeach McFadden under Rule 607 by eliciting detailed facts of prior incidents (guns, police calls)	Rule 607 permits attacking witness credibility; details relevant to show prior falsehoods	Impeachment should be limited to contradiction; detailed firearm/police facts were unfairly prejudicial and unnecessary	Prosecution could impeach that prior confrontations occurred, but eliciting detailed, firearm-centered facts was disproportionate and unfairly prejudicial under Rule 403; admission of those details was error
Whether the erroneous admission was harmless	State: overall evidence supported convictions	Williams: firearm-focused details likely undercut self-defense and were highly prejudicial	Error was not harmless given the centrality of firearms and self-defense; convictions reversed and remanded for new trial

Bowman v. State, 422 S.C. 19, 809 S.E.2d 232 (2018) (limits on rebuttal once defendant "opens the door")
State v. Young, 378 S.C. 101, 661 S.E.2d 387 (2008) (cross-examining accused about particular bad acts when accused offers good-character evidence)
State v. Wilson, 345 S.C. 1, 545 S.E.2d 827 (2001) (unfair prejudice defined under Rule 403)
Ellenburg v. State, 367 S.C. 66, 625 S.E.2d 224 (2006) (permitted responsive evidence limited to the scope of the door opened)
State v. Heyward, 426 S.C. 630, 828 S.E.2d 592 (2019) (testimony in response must be proportional to the topic opened)
Robertson v. Maryland, 205 A.3d 995 (Md. 2019) (doctrine of opening the door permits otherwise inadmissible evidence only to the extent necessary)