## Facts

- Donny Brown shot and killed Shane Hammond during a dispute that began over rent.
- The day before the shooting, Brown physically attacked Hammond during an argument; Hammond left.
- Hammond returned the next day to retrieve his belongings; Brown told him to leave, and a fight occurred inside Brown’s home.
- Brown admitted the shooting but claimed he acted in self-defense, asserting he feared Hammond would kill him.
- Brown testified that during the struggle he saw his gun (kept accessible in the home), grabbed it, and fired multiple times as Hammond allegedly charged and continued attacking.
- Over objection, the State presented testimony from Brown’s wife and grandson that Brown often became violent when angry and routinely kept a gun on or near him.
- The jury convicted Brown of murder.

## Issues

1. Whether testimony that Brown became violent when angry and habitually kept a gun available was inadmissible propensity evidence under Rule 404(a) when offered against a defendant claiming self-defense.
2. Whether the challenged evidence was admissible for non-propensity purposes, including rebuttal of self-defense and explaining the context of the incident and witness conduct.
3. If any portion was admitted in error, whether the error was prejudicial or harmless in light of the whole record.

## Decision

- The Supreme Court of South Carolina affirmed the murder conviction (affirmed as modified).
- The court held the testimony regarding Brown’s violence when angry and ready access to a gun was admissible in the context of rebutting Brown’s self-defense theory and explaining circumstances surrounding the confrontation.
- Alternatively, any evidentiary error did not warrant reversal because it was harmless given the strength of the remaining evidence supporting the verdict.

## Legal Principles

- Character evidence offered solely to prove conduct in conformity with a trait is generally barred by Rule 404(a), but evidence with a legitimate non-propensity relevance may be admitted.
- When a defendant asserts self-defense, the State may introduce relevant evidence tending to show the defendant was the aggressor or that the claimed fear and use of force were not reasonable.
- Evidence that explains witness behavior or the situational context of a charged event may be admissible even if it incidentally reflects on the defendant’s character.
- An evidentiary error warrants reversal only if it is prejudicial; an error is harmless when there is no reasonable probability it affected the verdict considering the entire record.

## Conclusion

The court upheld Brown’s murder conviction, ruling that testimony about his violence when angry and habitual access to a gun was properly admitted to rebut his self-defense claim and provide context, and that any improper admission was harmless given the other evidence.


State v. Brown, 345 S.C. 66, 543 S.E.2d 552 (2001)