State v. James H. Baldwin ( 2022 )

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.
James Harold Baldwin, Appellant.
Appellate Case No. 2019-001923
Appeal From Chester County
Daniel Dewitt Hall, Circuit Court Judge
Unpublished Opinion No. 2022-UP-444
Submitted November 1, 2022 – Filed December 7, 2022
AFFIRMED
Appellate Defender David Alexander, of Columbia, for
Appellant.
Attorney General Alan McCrory Wilson, Deputy
Attorney General Donald Zelenka, Senior Assistant
Deputy Attorney General Melody Brown, and Assistant
Attorney General Jonathan Scott Matthews, all of
Columbia, and Solicitor Randy E. Newman, Jr., of
Lancaster, all for Respondent.
PER CURIAM: James H. Baldwin appeals his conviction for murder and
sentence of life imprisonment. On appeal, Baldwin argues the trial court erred by
(1) allowing a forensic pathologist to testify beyond the scope of her expertise and
(2) admitting an irrelevant and prejudicial photo of Baldwin and the Sheriff of
Chester County. We affirm.
1. The trial court did not err in allowing the forensic pathologist's testimony
because she did not testify beyond the scope of her expertise when she testified
about the cause and manner of Judy Baldwin's death. See State v. Chavis, 412 S.C.
101, 106, 771 S.E.2d 336, 338 (2015) ("The qualification of an expert witness and
the admissibility of the expert's testimony are matters within the trial court's sound
discretion."); id. ("A trial court's decision to admit or exclude expert testimony will
not be reversed absent a prejudicial abuse of discretion."); id. ("An abuse of
discretion occurs when the conclusions of the [trial] court are either controlled by
an error of law or are based on unsupported factual conclusions."); State v.
Commander, 396 S.C. 254, 265, 721 S.E.2d 413, 419 (2011) (stating "[i]t is
well-established in South Carolina that a medical professional, qualified as an
expert, may render an opinion concerning the scientific bases of a victim's injuries
or death in a criminal trial"); id. at 269, 721 S.E.2d at 421("[A]n expert in forensic
pathology's opinion testimony as to cause and manner of death is admissible . . . so
long as the expert does not opine on the criminal defendant's state of mind or guilt
or testify on matters of law in such a way that the jury is not permitted to reach its
own conclusion concerning the criminal defendant's guilt or innocence.").
2. The trial court erred in admitting a Facebook photo of Baldwin and the Sheriff
of Chester County that was not relevant to a pertinent issue, but the error was
harmless because it did not affect the verdict. See State v. Chavis, 412 S.C. 101,
109, 771 S.E.2d 336, 340 (2015) ("An appellate court generally will decline to set
aside a conviction due to insubstantial errors not affecting the result."); id. at
109-10, 771 S.E.2d at 340 ("Whether an error is harmless depends on the
circumstances of the particular case. No definite rule of law governs this finding;
rather, the materiality and prejudicial character of the error must be determined
from its relationship to the entire case."); State v. Langley, 334 S.C. 643, 647-48,
515 S.E.2d 98, 100 (1999) ("Even if the evidence was not relevant and thus
wrongly admitted by the trial judge, its admission may constitute harmless error if
the irrelevant evidence did not affect the outcome of the trial.").
AFFIRMED. 1
1
We decide this case without oral argument pursuant to Rule 215, SCACR.
GEATHERS, MCDONALD, and HILL, JJ., concur.