State v. Randy D. Marchbanks

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.

Randy Doyle Marchbanks, Appellant.

Appellate Case No. 2021-001533

Appeal From Pickens County
Perry H. Gravely, Circuit Court Judge

Unpublished Opinion No. 2026-UP-093
Submitted January 1, 2026 – Filed February 25, 2026

AFFIRMED

Chief Appellate Defender Wanda H. Carter, of
Columbia, for Appellant.

Attorney General Alan McCrory Wilson and Senior
Assistant Attorney General Mark Reynolds Farthing,
both of Columbia; and Solicitor Cynthia Smith Crick, of
Greenville, all for Respondent.

PER CURIAM: Randy Doyle Marchbanks appeals his convictions for
discharging a firearm into a dwelling and pointing and presenting a firearm and his
sentence of four years' imprisonment, suspended to time served with three years of
probation. On appeal, Marchbanks argues the trial court erred in denying his
request to present a witness's virtual testimony. We affirm pursuant to Rule
220(b), SCACR.

We hold this issue is not preserved for appellate review because the substance of
the testimony was not sufficiently clear to enable this court to determine whether
Marchbanks was prejudiced by its exclusion. See State v. Douglas, 369 S.C. 424,
429, 632 S.E.2d 845, 847-48 (2006) ("The admission or exclusion of evidence is a
matter addressed to the sound discretion of the trial court and its ruling will not be
disturbed in the absence of a manifest abuse of discretion accompanied by
probable prejudice."); Rule 103(a)(2), SCRE (explaining that "[e]rror may not be
predicated upon a ruling" excluding evidence unless "the substance of the evidence
and the specific evidentiary basis supporting admission were made known to the
court by offer or were apparent from the context"); State v. Jenkins, 322 S.C. 360,
367, 474 S.E.2d 812, 816 (Ct. App. 1996) ("The reason for the rule requiring a
proffer of excluded evidence is to enable the reviewing court to discern
prejudice.").

AFFIRMED.1

WILLIAMS, C.J., and THOMAS and CURTIS, JJ., concur.

1
We decide this case without oral argument pursuant to Rule 215, SCACR.