State v. Christova P. Knowlin
CourtCourt of Appeals of South Carolina
Date FiledNovember 12, 2026
Docket2026-UP-479
StatusUnpublished
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Full Opinion
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.
Christova Pierre Knowlin, Appellant
Appellate Case No. 2025-000314
Appeal From Horry County
Michael G. Nettles, Circuit Court Judge
Unpublished Opinion No. 2026-UP-479
Submitted October 2, 2026 โ Filed November 12, 2026
AFFIRMED
Deputy Chief Appellate Defender for Capital Appeals
David Alexander, of Columbia, for Appellant.
Attorney General Alan McCrory Wilson and Assistant
Attorney General Brian Hollis Gibbs, both of Columbia;
and Solicitor Jimmy A. Richardson, II, of Conway, all for
Respondent.
PER CURIAM: Christova Pierre Knowlin appeals his conviction for domestic
violence of a high and aggravated nature (DVHAN) and sentence of twenty years'
imprisonment. On appeal, he argues the trial court abused its discretion by (1)
refusing to allow him to impeach a key fact witness with her pending drug charge
and (2) allowing the State to ask Victim's mother about the impact of the crime on
Victim's mother's life and enter into evidence a photograph of Victim prior to her
injuries, violating Rule 403 of the South Carolina Rules of Evidence. We affirm
pursuant to Rule 220(b), SCACR.
1. We hold any error in prohibiting Knowlin from cross-examining the key
witness on her pending drug charge was harmless beyond a reasonable doubt
because the limitation on cross-examination did not contribute to the verdict. See
State v. Graham, 314 S.C. 383, 386, 444 S.E.2d 525, 527 (1994) ("A violation of
the defendant's Sixth Amendment right to confront the witness is not per se
reversible error. This [c]ourt must determine whether the 'error was harmless
beyond a reasonable doubt.'" (citation omitted) (quoting Delaware v. Van Arsdall,
475 U.S. 673, 684 (1986))); State v. Collins, 409 S.C. 524, 537, 763 S.E.2d 22, 29
(2014) ("The harmless error rule generally provides that an error is harmless
beyond a reasonable doubt if it did not contribute to the verdict obtained."); State v.
Salley, 398 S.C. 160, 172, 727 S.E.2d 740, 746 (2012) ("Whether an error is
harmless depends on the particular circumstances of the case, and therefore a
reviewing court must look to the entire record to determine the effect the error had
on the verdict."); Van Arsdall, 475 U.S. at 684 (providing that whether an
erroneous limitation on cross-examination is harmless in a particular case depends
on the facts of each case as well as a set of non-exhaustive factors including: "the
importance of the witness' testimony in the prosecution's case, whether the
testimony was cumulative, the presence or absence of evidence corroborating or
contradicting the testimony of the witness on material points, the extent of
cross-examination otherwise permitted, and of course the overall strength of the
prosecution's case"); State v. Mizzell, 349 S.C. 326, 334, 563 S.E.2d 315, 319
(2002) (applying the Van Arsdall factors); State v. Curry, 370 S.C. 674, 682, 636
S.E.2d 649, 653 (Ct. App. 2006) (holding a limitation on cross-examination was
harmless where the testimony was cumulative and independent, competent
evidence supported the verdict).
2. Initially, we hold the trial court did not abuse its discretion by allowing the
State to admit a photograph of Victim prior to her injuries because the photograph
was relevant to show whether Victim suffered great bodily harmโan element of
the offense, and the probative value of the photograph was not substantially
outweighed by the danger of unfair prejudice. See State v. Williams, 432 S.C. 515,
521, 854 S.E.2d 166, 169 (Ct. App. 2021) ("In criminal cases, this court only
reviews errors of law."); State v. Rosemond, 335 S.C. 593, 596, 518 S.E.2d 588,
589-90 (1999) ("The relevance, materiality[,] and admissibility of photographs are
matters within the sound discretion of the trial court and a ruling will be disturbed
only upon a showing of an abuse of discretion."); State v. Douglas, 369 S.C. 424,
429-30, 632 S.E.2d 845, 848 (2006) ("An abuse of discretion occurs when the
conclusions of the trial court either lack evidentiary support or are controlled by an
error of law."); Rule 401, SCRE (providing that to be relevant, evidence must have
a "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 (providing that relevant evidence "may be
excluded if its probative value is substantially outweighed by the danger of unfair
prejudice, confusion of the issues, or misleading the jury, or by considerations of
undue delay, waste of time, or needless presentation of cumulative evidence");
State v. Gilchrist, 329 S.C. 621, 630, 496 S.E.2d 424, 429 (Ct. App. 1998) ("Unfair
prejudice does not mean the damage to a defendant's case . . . ; rather it refers to
evidence which tends to suggest decision on an improper basis." (quoting United
States v. Bonds, 12 F.3d 540, 567 (6th Cir. 1993))); S.C. Code Ann.
ยง 16-25-20(A)(1) (Supp. 2025) (providing domestic violence occurs when an
individual causes "physical harm or injury to a person's own household member");
S.C. Code Ann. ยง 16-25-65(A)(1) (Supp. 2025) (providing that a person is guilty of
DVHAN when he commits domestic violence "under circumstances manifesting
extreme indifference to the value of human life and great bodily injury to the
victim results"); S.C. Code Ann. ยง 16-25-10(2) (Supp. 2025) (defining "great
bodily injury" for purposes of the DVHAN statute as "injury which causes a
substantial risk of death or which causes serious, permanent disfigurement or
protracted loss or impairment of the function of a bodily member or organ"); State
v. Salley, 398 S.C. 160, 170, 727 S.E.2d 740, 745 (2012) (holding a photograph of
the victim while alive, which showed she was "healthy and vibrant," was properly
admitted to corroborate the pathologist's testimony that her sickle cell trait was not
outwardly apparent and to counter "an impression of a sickly and fragile child,
which may have affected the establishment of guilt," purposes independent of
arousing the jury's sympathy). Further, we hold the trial court did not abuse its
discretion by allowing the State to admit Victim's mother's testimony about the
effect of Victim's injuries on Victim's mother because the probative value of the
testimony was not substantially outweighed by the danger of unfair prejudice. See
Williams, 432 S.C. at 521, 854 S.E.2d at 169 ("In criminal cases, this court only
reviews errors of law."); State v. Langley, 334 S.C. 643, 647, 515 S.E.2d 98, 100
(1999) ("A trial [court] is accorded broad discretion in ruling on the admissibility
of the testimony."); State v. Irick, 344 S.C. 460, 464, 545 S.E.2d 282, 284 (2001)
("An abuse of discretion arises from an error of law or a factual conclusion that is
without evidentiary support."); Rule 401, SCRE (providing that to be relevant,
evidence must have a "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 ("Although relevant, evidence
may be excluded if its probative value is substantially outweighed by the danger of
unfair prejudice, confusion of the issues, or misleading the jury, or by
considerations of undue delay, waste of time, or needless presentation of
cumulative evidence." (emphasis added)); State v. Adkins, 353 S.C. 312, 326, 577
S.E.2d 460, 468 (Ct. App. 2003) (holding the trial court did not abuse its discretion
by permitting brief testimony that the victim played sports and attended a
particular high school when the witness did not elaborate on "the victim's
relationship with the family or how he acquired any family nicknames").
AFFIRMED.1
GEATHERS, HEWITT, and VINSON, JJ., concur.
1
We decide this case without oral argument pursuant to Rule 215, SCACR.