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March 4, 2026 Get Citation Alerts Download PDF Add Note

State v. Shannon L. Bone

Court of Appeals of South Carolina

• Citations: None known
• Docket Number: 2022-000873

• Precedential Status: Non-Precedential

• Opinion

• Authorities (11)

• Cited By (0)

• Summaries (0)

• Similar Cases (0)

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Combined 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.

Shannon Lane Bone, Appellant.

Appellate Case No. 2022-000873

Appeal From Georgetown County
Benjamin H. Culbertson, Circuit Court Judge

Unpublished Opinion No. 2026-UP-105
Submitted January 2, 2026 – Filed March 4, 2026

AFFIRMED

Senior Appellate Defender Kathrine Haggard Hudgins, of
Columbia, for Appellant.

Attorney General Alan McCrory Wilson and Assistant
Attorney General Ambree Michele Muller, both of
Columbia; and Solicitor Jimmy A. Richardson, II, of
Conway, all for Respondent.

PER CURIAM: Shannon Lane Bone appeals her conviction for armed robbery
and sentence of life without parole. On appeal, Bone argues the trial court erred by
failing to suppress portions of her recorded interview with law enforcement
officers in which she volunteered to act as a confidential informant, she asked
about a reduction in her charge, and an officer questioned her about a separate
motor vehicle break-in. We affirm pursuant to Rule 220(b), SCACR.

We hold the trial court did not abuse its discretion in admitting the portions of the
recording in which Bone offered to act as a confidential informant and questioned
officers about a reduction in her charge because they were relevant to
demonstrating Bone's consciousness of guilt. 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."); State v. Lyles, 379 S.C. 328, 339, 665 S.E.2d 201, 207 (Ct. App.
2008) ("The trial judge's decision regarding the relevancy of evidence should only
be overturned for a clear abuse of discretion."); Pagan, 369 S.C. at 208, 631 S.E.2d
at 265 ("An abuse of discretion occurs when the conclusions of the trial court
either lack evidentiary support or are controlled by an error of law."); State v.
McDowell, 266 S.C. 508, 515, 224 S.E.2d 889, 892 (1976) ("As a general rule, any
guilty act, conduct, or statements on the part of the accused are admissible as some
evidence of consciousness of guilt."); State v. Martin, 403 S.C. 19, 26, 742 S.E.2d
42, 46 (Ct. App. 2013) ("This general rule applies to evidence of particular
acts . . . ."); Pagan, 369 S.C. at 209, 631 S.E.2d at 266 ("The critical factor to the
admissibility of evidence of [a guilty conscience] is whether the totality of the
evidence creates an inference that the defendant had knowledge that he was being
sought by authorities."); State v. Cartwright, 425 S.C. 81, 91-93, 819 S.E.2d 756,
761-62 (2018) (ruling a trial court did not abuse its discretion in admitting
evidence of the defendant's attempted suicide because "a clear and unmistakable
nexus link[ed] the suicide attempt to a guilty conscience derivative of the offence
for which the defendant [was] on trial"); see also United States v. Cardena, 842
F.3d 959, 992 (7th Cir. 2016) ("[A]n offer to cooperate to get oneself out of trouble
is relevant evidence tending to show consciousness of guilt."); United States v.
Levy, 578 F.2d 896, 900-01 (2nd Cir. 1978) (finding a defendant's offer to work as
an informant for the DEA "evidence[d] a consciousness of guilt" and showed the
defendant was aware "he was in serious difficulty with the law and needed to do
something to extricate himself").

We hold the trial court abused its discretion in admitting the portions of the
recording related to the alleged vehicle break-in because the risk of unfair
prejudice to Bone substantially outweighed the probative value of the information.
See Rule 403, SCRE ("[R]elevant[] 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."). However, such error was
harmless given the strong evidence of Bone's guilt of the charged offense, which
included witnesses observing Bone's license plate number on the robber's vehicle, a
witness identifying Bone's voice as belonging to the robber, phone records placing
Bone at the scene of the crime, and Bone's guilty conduct. See 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. Brown, 344 S.C. 70, 75, 543 S.E.2d 552, 554-55
(2001) ("Whether an error in the admission of evidence is harmless generally
depends upon its materiality in relation to the case as a whole."); State v. Mitchell,
286 S.C. 572, 573, 336 S.E.2d 150, 151 (1985) ("Error is harmless when it 'could
not reasonably have affected the result of the trial.'" (quoting State v. Key, 256 S.C.
90, 93, 180 S.E. 2d 888, 890 (1971))).

AFFIRMED.1

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

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