State v. Brown

818 S.E.2d 735 (2018)

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State v. Brown

South Carolina Supreme Court
818 S.E.2d 735 (2018)

Facts

Donte Brown (defendant) and Christopher Wilson were charged with robbing a Zaxby’s restaurant. Wilson was wearing a Global Positioning System (GPS) ankle monitor at the time, and Wilson’s GPS records showed that Wilson was at the Zaxby’s during the robbery. Wilson pleaded guilty, but the case against Brown went to trial. At trial, the State of South Carolina (plaintiff) presented the testimony of probation agent Steward Powell to authenticate the GPS records from Wilson’s monitor. Powell testified about how GPS ankle monitors work and how information from the ankle monitors is recorded. When asked if the information from GPS ankle monitors is accurate, Powell testified that the information is accurate and used in court “all the time.” Brown was ultimately convicted. The court of appeals affirmed the conviction, and Brown appealed to the South Carolina Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Kittredge, J.)

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