State v. David L. Hayden

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.

David Louis Hayden, Appellant.

Appellate Case No. 2022-001459

Appeal From Lancaster County
Paul M. Burch, Circuit Court Judge

Unpublished Opinion No. 2026-UP-012
Submitted November 3, 2025 – Filed January 14, 2026

AFFIRMED

Appellate Defender Gary Howard Johnson, II, of
Columbia, for Appellant.

Attorney General Alan McCrory Wilson and Assistant
Attorney General Joshua Abraham Edwards, both of
Columbia; and Solicitor Randy E. Newman, of
Lancaster, all for Respondent.

PER CURIAM: David Louis Hayden appeals his convictions for trafficking in
persons under eighteen years of age, first-degree criminal sexual conduct (CSC)
with a minor, and contributing to the delinquency of a minor, and concurrent
sentences of life without parole (LWOP) for trafficking in persons under eighteen
years of age, LWOP for first-degree CSC with a minor, and three years'
imprisonment for contributing to the delinquency of a minor. On appeal, Hayden
argues the trial court erred in preventing him from impeaching the minor victim's
(Victim's) credibility with evidence regarding an alleged false allegation (the
allegation) of sexual assault. We affirm pursuant to Rule 220(b), SCACR.

We hold any error of the trial court in preventing Hayden from introducing
evidence and cross-examining Victim regarding the allegation solely on the basis
the allegation occurred after the facts of this case was harmless because the
allegation was otherwise inadmissible under State v. Boiter. 1 See State v. Pagan,
369 S.C. 201, 208, 631 S.E.2d 262, 265 (2006) ("The admission of evidence is
within the discretion of the trial court and will not be reversed absent an abuse of
discretion."); Clark v. Cantrell, 339 S.C. 369, 389, 529 S.E.2d 528, 539 (2000)
("An abuse of discretion occurs when the trial court's ruling is based on an error of
law or, when grounded in factual conclusions, is without evidentiary support.");
State v. Taylor, 333 S.C. 159, 172, 508 S.E.2d 870, 876 (1998) ("[I]n order for this
[c]ourt to reverse a case based on the erroneous admission or exclusion of
evidence, prejudice must be shown."); State v. Byers, 392 S.C. 438, 444, 710
S.E.2d 55, 58 (2011) ("Prejudice occurs when there is reasonable probability the
wrongly admitted evidence influenced the jury's verdict."). Although Boiter
governs the admission of "prior false allegations" of a complainant, and this
allegation occurred subsequent to the events of the case, it nevertheless occurred
prior to the actual trial, and such an allegation may have the same potential
probative value; therefore, a Boiter analysis would still apply. See Boiter, 302 S.C.
at 383, 396 S.E.2d at 365 ("Evidence of prior false accusations by a complainant
may be probative on the issue of credibility."). Nevertheless, Hayden failed to
establish the allegation was admissible under a Boiter analysis. See State v. Reyes,
432 S.C. 394, 406, 853 S.E.2d 334, 340 (2020) ("Whether an error is harmless
depends on the circumstances of the particular case." (quoting State v. Mitchell,
286 S.C. 572, 573, 336 S.E.2d 150, 151 (1985))); id. ("Error is harmless when it
could not reasonably have affected the result of the trial." (quoting Mitchell, 286
S.C. at 573, 336 S.E.2d at 151)); Boiter, 302 S.C. at 383, 396 S.E.2d at 365 ("[I]n
deciding admissibility of evidence of a victim's prior accusation, the trial [court]
should first determine whether such accusation was false."); id. ("If the prior
allegation was false, the next consideration becomes remoteness in time."); id. at
383-84, 396 S.E.2d at 365 ("Finally, the trial court shall consider the factual
similarity between prior and present allegations to determine relevancy.").

1
302 S.C. 381, 396 S.E.2d 364 (1990).
AFFIRMED.2

MCDONALD, HEWITT, and TURNER, JJ., concur.

2
We decide this case without oral argument pursuant to Rule 215, SCACR.