Supreme Court of South Carolina

The State v. Donte Samar Brown

August 29, 2018424 S.C. 479

Summary

The South Carolina Supreme Court held that the State failed to properly authenticate GPS monitoring records, making their admission error, but found the error harmless beyond a reasonable doubt and affirmed the convictions. The Court also clarified the minimal authentication requirements for machine‑generated GPS data.

Holding

  • Whether the State properly authenticated the GPS monitoring records under Rule 901(b)(9) of the South Carolina Rules of Evidence.. The State failed to authenticate the GPS records; admission was error.
  • Whether the admission of unauthenticated GPS records was harmless beyond a reasonable doubt.. The error was harmless beyond a reasonable doubt; convictions affirmed.

Docket Appellate Case No. 2017-000094; Opinion No. 27836

Cited authorities

  • Fed. R. Evid. 901(b)(9)
  • Wis. Stat. § 907.02
  • Fed. R. Evid. 901
  • S.C. Code Ann. § 23-3-540

Cited by

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