context: Based on the foregoing, it is arguable the directed verdict issue is not preserved as defense counsel did not specifically renew his directed verdict motion at the conclusion of the evidence. Rather, he made only a general reference to renewing his "previous objections," a statement he made earlier which did not include his directed verdict motion.
citation_a.signal: see
citation_a.parenthetical: finding defense counsel's statement at the end of all the evidence that he was making the "standard motions" did not preserve the issue of directed verdict for appeal
citation_a.sentence: See State v. Bailey, 298 S.C. 1, 377 S.E.2d 581 (1989) (finding defense counsel’s statement at the end of all the evidence that he was making the “standard motions” did not preserve the issue of directed verdict for appeal); State v. Taylor, 333 S.C. 159, 508 S.E.2d 870 (1998) (noting a general or nonspecific objection presents no issue for appellate review); see also State v. Parler, 217 S.C. 24, 59 S.E.2d 489 (1950) (holding, under former Circuit Court Rule 76, the denial of the defendant’s directed verdict motion was not preserved for appeal where he failed to renew the motion after presenting evidence); Note to Rule 19, SCRCrimP (stating the rule “is substantially the substance of Circuit Court Rule 76”); State v. Adams, 332 S.C. 139, 144, 504 S.E.2d 124, 126-27 (Ct.App.1998) (finding appellant’s directed verdict motion was not preserved where the argument raised on appeal was not presented to the trial court, and “[m]oreover, the record does not reflect that Adams renewed the motion at the close of his case”) (citing, inter alia, State v. Parler, 217 S.C. 24, 59 S.E.2d 489 (1950) and the Note to Rule 19, SCRCrimP); State v. Harry, 321 S.C. 273, 277, 468 S.E.2d 76, 79 (Ct.App.1996) (“A motion for a directed verdict made at the close of the [state’s] case is not sufficient to preserve error unless renewed at the close of all the evidence, because once the defense has come forward with its proof, the propriety of a directed verdict can only be tested in terms of all the evidence.”) (alteration in original) (citation omitted).
citation_b.signal: see also
citation_b.identifier: 321 S.C. 273, 277
citation_b.parenthetical: "A motion for a directed verdict made at the close of the [state's] case is not sufficient to preserve error unless renewed at the close of all the evidence, because once the defense has come forward with its proof, the propriety of a directed verdict can only be tested in terms of all the evidence."
citation_b.sentence: See State v. Bailey, 298 S.C. 1, 377 S.E.2d 581 (1989) (finding defense counsel’s statement at the end of all the evidence that he was making the “standard motions” did not preserve the issue of directed verdict for appeal); State v. Taylor, 333 S.C. 159, 508 S.E.2d 870 (1998) (noting a general or nonspecific objection presents no issue for appellate review); see also State v. Parler, 217 S.C. 24, 59 S.E.2d 489 (1950) (holding, under former Circuit Court Rule 76, the denial of the defendant’s directed verdict motion was not preserved for appeal where he failed to renew the motion after presenting evidence); Note to Rule 19, SCRCrimP (stating the rule “is substantially the substance of Circuit Court Rule 76”); State v. Adams, 332 S.C. 139, 144, 504 S.E.2d 124, 126-27 (Ct.App.1998) (finding appellant’s directed verdict motion was not preserved where the argument raised on appeal was not presented to the trial court, and “[m]oreover, the record does not reflect that Adams renewed the motion at the close of his case”) (citing, inter alia, State v. Parler, 217 S.C. 24, 59 S.E.2d 489 (1950) and the Note to Rule 19, SCRCrimP); State v. Harry, 321 S.C. 273, 277, 468 S.E.2d 76, 79 (Ct.App.1996) (“A motion for a directed verdict made at the close of the [state’s] case is not sufficient to preserve error unless renewed at the close of all the evidence, because once the defense has come forward with its proof, the propriety of a directed verdict can only be tested in terms of all the evidence.”) (alteration in original) (citation omitted).