State v. Seidle ( 2024 )

THIS OPINION HAS NO PRECEDENTIAL VALUE. IT SHOULD NOT BE
CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING
EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.
THE STATE OF SOUTH CAROLINA
In The Court of Appeals
The State, Respondent,
v.
Bryan Austin Seidle, Appellant.
Appellate Case No. 2020-001485
Appeal From Florence County
Michael G. Nettles, Circuit Court Judge
Unpublished Opinion No. 2024-UP-147
Submitted April 1, 2024 – Filed May 1, 2024
AFFIRMED
Chief Appellate Defender Robert Michael Dudek, and
Appellate Defender Lara Mary Caudy, both of Columbia,
both for Appellant.
Attorney General Alan McCrory Wilson, Deputy
Attorney General Donald J. Zelenka, Senior Assistant
Deputy Attorney General Melody Jane Brown, and
Assistant Attorney General Joshua Abraham Edwards, all
of Columbia; and Solicitor Edgar Lewis Clements, III, of
Florence, all for Respondent.
PER CURIAM: Bryan Austin Seidle appeals his conviction for murder and his
sentence of thirty years' imprisonment. On appeal, Seidle argues the trial court
erred in excluding relevant evidence the victim was a registered sex offender and
the exclusion violated his due process rights to present a complete defense. We
affirm pursuant to Rule 220(b), SCACR.
We hold the trial court did not err in excluding the victim's sex offender status. See
State v. Baccus, 367 S.C. 41, 48, 625 S.E.2d 216, 220 (2006) ("In criminal cases,
the appellate court sits to review errors of law only."); id. ("This [c]ourt is bound
by the trial court's factual findings unless they are clearly erroneous."); State v.
Clasby, 385 S.C. 148, 154, 682 S.E.2d 892, 895 (2009) ("The trial [court] has
considerable latitude in ruling on the admissibility of evidence and [its] decision
should not be disturbed absent prejudicial abuse of discretion."); State v. Jones,
416 S.C. 283, 290, 786 S.E.2d 132, 136 (2016) ("An abuse of discretion occurs
when the trial court's ruling is based on an error of law or, when grounded in
factual conclusions, is without evidentiary support."); State v. Collins, 409 S.C.
524, 534, 763 S.E.2d 22, 28 (2014) ("A trial [court]'s decision regarding the
comparative probative value and prejudicial effect of evidence should be reversed
only in exceptional circumstances." (quoting State v. Adams, 354 S.C. 361, 378,
580 S.E.2d 785, 794 (Ct. App. 2003))). Additionally, we hold the victim's sex
offender status was not relevant, and even if it were relevant, the probative value
was substantially outweighed by the danger of unfair prejudice. See Rule 401,
SCRE ("'Relevant evidence' means evidence having any tendency to make the
existence of any fact that is of consequence to the determination of the action more
probable or less probable than it would be without the evidence."); Rule 403,
SCRE ("[E]vidence may be excluded if its probative value is substantially
outweighed by the danger of unfair prejudice . . . ."); State v. Dickerson, 341 S.C.
391, 400, 535 S.E.2d 119, 123 (2000) ("Unfair prejudice means an undue tendency
to suggest [a] decision on an improper basis."). Further, we hold because the
victim's sex offender status was not relevant, exclusion of this information did not
prevent Seidle from presenting a complete defense. See Chambers v. Mississippi,
410 U.S. 284, 302 (1973) ("In the exercise of this right, the accused, as is required
of the State, must comply with established rules of procedure and evidence
designed to assure both fairness and reliability in the ascertainment of guilt and
innocence."); State v. Day, 341 S.C. 410, 419-20, 535 S.E.2d 431, 436 (2000)
(holding that in cases where one pleading self-defense wishes to admit evidence of
other specific instances of violence directed at others, such instances must be
"closely connected at point of time or occasion with the homicide").
AFFIRMED. 1
GEATHERS, HEWITT, and VINSON, JJ., concur.
1
We decide this case without oral argument pursuant to Rule 215, SCACR.