State v. Antonio V. Barnes, Jr.

Court of Appeals of South Carolina·Decided August 5, 2026·No. 2023-001390·Unpublished

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.

Antonio Vashon Barnes, Jr., Appellant.

Appellate Case No. 2023-001390

Appeal From Richland County Clifton Newman, Circuit Court Judge

Unpublished Opinion No. 2026-UP-393 Heard April 7, 2026 – Filed August 5, 2026

AFFIRMED IN PART AND REVERSED IN PART AND REMANDED

Senior Appellate Defender Lara Mary Caudy, of Columbia, for Appellant.

Attorney General Alan McCrory Wilson, Deputy Attorney General Donald J. Zelenka, Senior Assistant Deputy Attorney General Melody Jane Brown, and Assistant Attorney General William Joseph Maye, all of Columbia, for Respondent.

PER CURIAM: Antonio Vashon Barnes, Jr. appeals his convictions and concurrent sentences of thirty-five years' imprisonment for murder and five years' imprisonment for possession of a weapon during a violent crime. On appeal, Barnes argues the trial court (1) erred by denying him immunity from prosecution under the Protection of Persons and Property Act1 (the Act); (2) erred by failing to properly instruct the jury on the defense of habitation; (3) abused its discretion by admitting evidence of Barnes's possession and distribution of marijuana and possession of firearms and ammunition; (4) abused its discretion by admitting lyrics from a song Barnes rapped and posted online; (5) abused its discretion by refusing to admit certain video footage of Barnes as a prior consistent statement; and (6) erred by refusing to grant a new trial based on cumulative error. We reverse and remand for a new trial. FACTS/PROCEDURAL HISTORY

In 2022, Barnes was indicted for murder and possession of a weapon during the commission of a violent crime in connection with the killing of his roommate, Antonio Dash, and Eric Griffin. Barnes moved for immunity from prosecution under the Act, and the trial court held an immunity hearing. The trial court denied Barnes immunity from prosecution, and a jury found Barnes guilty in December 2022 on both charges. Barnes subsequently filed a motion for a new trial, which the trial court denied. This appeal followed. ISSUES ON APPEAL I. Did the trial court err by denying Barnes immunity from prosecution under the Act?

II. Did the trial court abuse its discretion by admitting lyrics from a song Barnes rapped and posted on YouTube under Rules 402, 403, and 404(b), SCRE, and when the State failed to disclose the evidence to Barnes in violation of Rule 5 of the South Carolina Rules of Criminal Procedure?

III. Did the trial court abuse its discretion by refusing to admit Barnes's Exhibit No. 108 (a prior consistent statement) pursuant to Rule 801(d)(1)(B), SCRE?

IV. Did the trial court abuse its discretion by admitting evidence of Barnes's marijuana possession, prior marijuana distribution, and possession of unrelated

1 S.C. Code Ann. § 16-11-410, et. seq. (2015).

firearms and ammunition under Rules 402, 403, and 404(b) of the South Carolina Rules of Evidence?

V. Did the trial court err in instructing the jury on the defense of habitation as requested by Barnes?

VI. Did the trial court err by refusing to grant a new trial based on the cumulative effect of the trial errors?

LAW/ANALYSIS

I. Immunity Hearing

Barnes argues the trial court erred in denying him immunity because he proved by a preponderance of the evidence that he was entitled to immunity under the Act. He contends the evidence showed he was immune under (1) the common law defense of habitation, (2) the common law defense of self-defense, (3) section 16-11-440(A) of the South Carolina Code, and (4) section 16-11-440(C) of the Code. We disagree. "A defendant's entitlement to immunity from prosecution under the [Act] must be decided pretrial using a preponderance of the evidence standard." State v. Glenn, 429 S.C. 108, 116, 838 S.E.2d 491, 495 (2019). "This court reviews an immunity determination for abuse of discretion." Id. "A trial court abuses its discretion when its ruling is based on an error of law, or when grounded in factual conclusions, is without evidentiary support." Id. "In determining the validity of an immunity hearing's outcome, 'this court cannot reweigh the evidence or second-guess the [circuit] court's assessment of witness credibility.'" State v. Rosenbaum, 438 S.C. 91, 102, 882 S.E.2d 180, 186 (Ct. App. 2022) (alteration in original) (quoting State v. Oates, 421 S.C. 1, 17, 803 S.E.2d 911, 920 (Ct. App. 2017)).

Self-defense

"A person who uses deadly force as permitted by the [Act] or another applicable provision of law is justified . . . and is immune from criminal prosecution . . . ." § 16-11-450(A). Our supreme court has recognized that "'another applicable provision of law' includes the common law of self-defense." Glenn, 429 S.C. at 117, 838 S.E.2d at 496. "Accordingly, a trial court should first consider whether the defendant has proved the elements of self-defense by a preponderance of the evidence." Id. at 118, 838 S.E.2d at 496. "If the defendant has failed to meet the elements of reasonable fear or the duty to retreat, the court should then determine whether section 16-11-440(A) or (C) is applicable." Id. To establish a case of self-defense, a defendant must establish four elements:

First, the defendant must be without fault in bringing on the difficulty. Second, the defendant must have actually believed he was in imminent danger of losing his life or sustaining serious bodily injury, or he actually was in such imminent danger. Third, if his defense is based upon his belief of imminent danger, a reasonably prudent man of ordinary firmness and courage would have entertained the same belief. If the defendant actually was in imminent danger, the circumstances were such as would warrant a man of ordinary prudence, firmness and courage to strike the fatal blow in order to save himself from serious bodily harm or losing his own life. Fourth, the defendant had no other probable means of avoiding the danger of losing his own life or sustaining serious bodily injury than to act as he did in this particular instance.

State v. Douglas, 411 S.C. 307, 318, 786 S.E.2d 232, 238–39 (Ct. App. 2014). "[T]he last element, i.e., the duty to retreat, need not be shown when seeking immunity under the Act." Id. at 318, 786 S.E.2d at 239.

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