State v. Eastwood: Polygraph-Context Evidence and False Confessions Under South Carolina Rule 403

I. Introduction

In State v. Kenneth Henry Eastwood, Opinion No. 28308 (S.C. Sup. Ct. Nov. 19, 2025), the Supreme Court of South Carolina addressed a narrow but important evidentiary question with broad implications: when, if ever, may a criminal defendant present evidence that police told him he had failed a polygraph examination in order to support a false-confession defense?

The Court held that the trial court erred in excluding such evidence under both Rule 702 and Rule 403 of the South Carolina Rules of Evidence (SCRE), but nonetheless affirmed the conviction on the ground that the error was harmless. In doing so, the Court:

• Clarified that evidence a defendant was told he “failed” a polygraph, when offered to explain the psychological context of a confession rather than to prove guilt or innocence, is not governed by Rule 702’s scientific-reliability requirements.
• Held that, in the context of a false confession theory, such evidence has significant probative value under Rule 403 and is generally not unduly confusing or unfairly prejudicial if properly limited.
• Limited the reach of State v. Wright, 322 S.C. 253, 471 S.E.2d 700 (1996), to its facts, rejecting Wright’s broad suggestion that a failed-polygraph-followed-by-confession can only bolster the confession’s truth.
• Reaffirmed that even evidentiary errors touching on the defense theory may be harmless if the core substance of the defense is still presented and the verdict is unlikely to have been affected.

The decision thus marks a significant development in South Carolina’s law of confessions, polygraph-related evidence, and Rule 403 balancing, particularly where the defense asserts an internalized false confession.

II. Factual and Procedural Background

A. The Homicide and Investigation

Four days after the disappearance of Cara Hodges (“Victim”), her body was discovered in a wooded area beside a dirt road. She had been strangled, and her clothes and the alleged ligature (an extension cord) were never recovered.

Investigators learned that Kenneth H. Eastwood was the last person seen with the Victim. Eastwood agreed to accompany investigators to the Orangeburg County Sheriff’s Office. After receiving Miranda warnings, he admitted to drinking with the Victim and said she had stayed at his house overnight but was gone when he awoke.

After about an hour of questioning, Eastwood agreed to take a polygraph. Following the test, officers told Eastwood that he had failed the polygraph and that they believed he was lying. He then consented to a DNA swab and a search of his home and car, and officers photographed scratches on his chest, which he claimed were from a cat.

After the search concluded, officers left Eastwood at home but impounded his car. According to Eastwood, he did not sleep that night. The next morning he walked approximately five miles to the grocery store where he worked.

B. The Admissions and Confession

At the grocery store, Eastwood told his boss, Brian Lauder:

• “I won’t be in today, and I probably won’t be back.”
• When asked why, he stated, “I killed her. I strangled her.”
• He said he did so because “she wouldn’t leave me alone.”
• He told Lauder he “put her in the car and dumped her on the side of the road.”

Lauder told him to turn himself in; Eastwood replied he would do so once DNA results came back because “they’ll know and I’ll confess then.” Lauder promptly reported the conversation to the police.

Police arrested Eastwood, who then gave a detailed confession: he said he strangled the Victim at his home with an extension cord, placed her body in his trunk, and left her in the woods beside a road, discarding her clothes and the extension cord in a dumpster. Those items were never recovered.

C. The Defense at Trial

Eastwood did not testify. Instead, his defense centered on the claim that his confession was false, the product of an internalized false confession. His expert, Alan Hirsch, a scholar of false confessions, testified about:

• How innocent individuals have, in other documented cases, confessed falsely to crimes.
• The concept of an internalized false confession, in which the suspect comes to believe he committed the crime.
• Two core ingredients:
  • (1) the suspect is confronted with “allegedly objective evidence of guilt” (e.g., DNA, eyewitness identification, or an asserted failed polygraph), and
  • (2) the suspect develops a distrust of his own memory (often due to factors like intoxication, fatigue, or psychological vulnerability).

Hirsch testified that Eastwood’s confession fit this internalized false confession model: he was allegedly alcohol-impaired, sleep-deprived, and confronted with claims that he was lying and that the police had “objective” grounds to distrust his story.

D. The Excluded Polygraph Evidence

Critical to Hirsch’s theory was the fact that Eastwood was told he had failed a polygraph test shortly before confessing. Eastwood sought to introduce, through Hirsch, the fact that:

• Eastwood took a polygraph, and
• Police told him he failed it.

He did not seek to introduce the polygraph results as scientific proof of guilt or innocence, but rather as part of the psychological environment that led to his alleged false confession.

The trial court:

• Excluded the evidence under Rule 702, finding no showing of polygraph reliability or compliance with expert-testimony criteria.
• Also excluded it under Rule 403, reasoning that:
  • It would “confuse the issues” by inviting the jury to consider polygraph reliability, and
  • It could cause unfair prejudice to Eastwood by bolstering the confession (suggesting that a confession following a failed polygraph is more likely true).

The jury, after about ninety minutes of deliberation, convicted Eastwood of murder.

E. The Appeal

On appeal, the sole issue before the Supreme Court was whether the trial court erred in refusing to allow Eastwood to present evidence that he had taken—and been told he had failed—a polygraph test, when this evidence was offered to support his false confession defense.

The Court held that:

• The trial court erred in excluding this evidence.
• But the error was harmless; it did not affect the jury’s verdict.
• Accordingly, the conviction was affirmed.

III. Summary of the Opinion

A. Rule 702: Inapplicable to the Narrow Use of Polygraph Evidence

The Court concluded the trial court misapplied Rule 702, SCRE. Eastwood was not offering polygraph evidence as scientific proof that the test was accurate or that the result itself was true. Rather, he sought to show:

• That he took a polygraph, and
• That police told him he failed it,

solely as part of the psychological setting in which his confession was made and to bolster Hirsch’s opinion that Eastwood’s confession was internalized and false.

Because the reliability of the polygraph as a scientific instrument was not at issue, Rule 702’s expert-reliability framework was unnecessary. Hirsch had already been qualified as an expert on false confessions; his ability to testify that the police confronted Eastwood with an alleged failed polygraph was an issue of relevance and prejudice, governed by Rule 403, not Rule 702.

B. Rule 403: Probative Value vs. Confusion and Unfair Prejudice

Under Rule 403, SCRE, relevant evidence “may be excluded if its probative value is substantially outweighed” by risks such as unfair prejudice or confusion of the issues. The trial court thought the polygraph evidence would confuse and unfairly prejudice the jury. The Supreme Court disagreed.

On “confusion of the issues,” the Court emphasized that:

• The evidence was directly relevant to a central issue: whether Eastwood’s confession was false.
• Hirsch’s theory required showing Eastwood had been confronted with allegedly objective evidence of guilt, and the “failed” polygraph fit squarely into that category.
• There was minimal risk that the jury would be diverted into deciding polygraph reliability; any residual risk could be managed with a limiting instruction under Rule 105, SCRE, confining the jury’s consideration to the fact that Eastwood was told he failed the polygraph.
• Mere “curiosity” about the actual result or reliability of the polygraph does not amount to legal “confusion” justifying exclusion.

On “unfair prejudice,” the Court rejected the notion that a confession following a purportedly failed polygraph can only be interpreted as bolstering the confession’s truth. That view may have had force in earlier cases but is incompatible with modern false confession theory. In a false confession context, the jury may reasonably infer:

• The failed-polygraph claim pressured the suspect into confessing falsely, or
• It confirmed

Because multiple reasonable inferences are possible, the polygraph evidence is neither inherently nor exclusively prejudicial to the defendant. In fact, in this case it was evidence the defense wanted and needed.

C. Limitation of State v. Wright to Its Facts

The trial court relied on State v. Wright, 322 S.C. 253, 471 S.E.2d 700 (1996), which involved a confession following a polygraph. In Wright, the Court suggested that evidence a defendant was told he failed a polygraph would “only” allow an inference that the confession was true and would therefore “bolster” it.

In Eastwood, the Supreme Court:

• Recognized the trial court’s reliance on Wright but
• Limited Wright to its facts, expressly rejecting its broad statement that only one inference (truth of confession) can be drawn when a confession follows a failed polygraph.
• Held that in a false confession theory scenario, the existence of alternative, defense-favorable inferences makes that Wright dictum untenable.

D. Harmless Error: The Verdict Stands

Although the Supreme Court found evidentiary error in excluding the polygraph-context evidence, it held the error was harmless.

Applying the harmless-error framework from cases such as State v. Pagan, 369 S.C. 201, 631 S.E.2d 262 (2006), and State v. Reyes, 432 S.C. 394, 853 S.E.2d 334 (2020), the Court asked whether the error reasonably affected the verdict. It concluded it did not, because:

• Hirsch already testified to the essence of the internalized false confession theory—namely, that police told Eastwood they believed he was lying, and that, combined with his alcohol use and sleep deprivation, could have caused him to doubt his own memory and falsely confess.
• The polygraph detail would have only “burnished” or added detail to Hirsch’s theory; its absence did not “materially dilute” the substance of his testimony (illustrated by the Court’s colorful analogy that this was not akin to “Einstein [being] stopped from including the ‘m’ in E = mc²”).
• There was significant non-confession evidence supporting guilt:
  • Eastwood’s unsolicited admission to his boss, Lauder, before any police interrogation that day.
  • Scratches and bruises on Eastwood’s torso suggesting a struggle and likely caused by a human, not a cat.
  • Victim’s body being found unclothed and strangled beside a road, consistent in key respects with Eastwood’s confession.
  • Some DNA evidence under Victim’s fingernails (even if explainable by prior contact).
  • Contextual evidence such as a space heater positioned in a way that might have required an extension cord.
• Although the physical evidence was “limited” and not overwhelming, the Court concluded the omitted polygraph detail did not reasonably tip the scales on the ultimate question of guilt.

Accordingly, the Court affirmed the conviction.

IV. Detailed Analysis

A. Precedents and Authorities Cited

1. Crane v. Kentucky, 476 U.S. 683 (1986)

The Court relied on Crane to underscore the constitutional backdrop: the defendant’s right to present a meaningful defense, particularly one that contests the reliability of a confession.

Crane held that excluding evidence about the “physical and psychological environment that yielded the confession” could violate the defendant’s constitutional right to present a complete defense. The U.S. Supreme Court explained that, if the defendant is barred from describing the circumstances of the confession, he is “effectively disabled” from answering the crucial juror question: “If the defendant is innocent, why did he previously admit his guilt?”

In Eastwood, although no explicit constitutional claim was pressed, the Court invoked Crane to emphasize the importance—and probative force—of contextual evidence surrounding a confession. It used Crane not to find a constitutional violation, but to strengthen the argument that, as a matter of evidence law, the polygraph-context evidence had substantial probative value and should not have been lightly excluded.

2. State v. Wright, 322 S.C. 253, 471 S.E.2d 700 (1996)

In Wright, the defendant’s confession came shortly after he was told by a polygraph examiner that the test indicated deception and the results could be admissible in court. The defense theory was coercion, not internalized false confession, and the case did not involve an expert like Hirsch.

The Court in Wright stated that admitting evidence that the defendant was told he failed the polygraph would “only” support an inference that:

• The confession was truthful, and
• The answers during the polygraph were untruthful,

thereby “bolstering” the confession and undermining the defense.

In Eastwood, the Supreme Court:

• Recognized that the trial court believed itself bound by Wright’s analysis.
• “Limited that decision to its facts,” carefully cabining Wright’s “only inference” language.
• Clarified that in the context of a false confession theory, the inference landscape is different: a failed-polygraph assertion may also plausibly support the defense that the suspect was pressured into a false confession.

This limitation of Wright is one of the key doctrinal moves in Eastwood. It signals that earlier skepticism about polygraph-related evidence cannot be applied mechanically when the defense seeks to use such evidence to explain the psychological dynamics of a confession, rather than to prove the truth of the polygraph itself.

3. Rogers v. Commonwealth, 86 S.W.3d 29 (Ky. 2002)

The Court favorably cited Rogers, a Kentucky case that addressed a nearly identical issue. In Rogers, the defense presented a false confession theory and sought to introduce polygraph-related evidence as part of the confession context. The Kentucky Supreme Court held that barring any reference to the polygraph “pulled the proverbial rug out from under [the] defense,” preventing the defendant from explaining the factual circumstances he alleged caused the false confession.

South Carolina’s Supreme Court used Rogers as persuasive authority to emphasize:

• The critical importance of allowing a defendant to tell the full story of how his confession came about.
• The risk that excluding polygraph-context evidence in a false confession case may cripple the defense theory.

While stopping short of reversal here, the Court’s reliance on Rogers strongly suggests that, in a closer evidentiary record, such exclusion might warrant a new trial.

4. State v. Cope, 405 S.C. 317, 748 S.E.2d 194 (2013), overruled in part on other grounds by State v. Wallace, 440 S.C. 537, 892 S.E.2d 310 (2023)

Cope concerned the scope of permissible testimony by a false confession expert. The Court upheld the exclusion of detailed accounts of other historical false confession cases but permitted the expert to testify extensively about:

• The existence of false confessions, and
• The general features and causes of such confessions.

In Eastwood, the Court analogized:

• Just as in Cope, where the expert’s inability to detail prior cases did not fatally undermine the defense,
• So here, Hirsch’s inability to mention the polygraph did not “remove an essential part of his theory.”

This comparison was used to support the **harmless error** conclusion: despite the evidentiary error, the jury still heard a “functionally complete” version of the false confession theory.

5. State v. Pagan, 369 S.C. 201, 631 S.E.2d 262 (2006), and State v. Reyes, 432 S.C. 394, 853 S.E.2d 334 (2020)

These cases provide the general harmless-error framework:

• Appellate courts will not overturn convictions for “insubstantial errors” that do not affect the result.
• The question is whether the error contributed to the verdict in a reasonable sense.

The Court in Eastwood applied this standard directly, analyzing whether the exclusion of the polygraph-context detail meaningfully affected the defense’s ability to argue internalized false confession or the jury’s evaluation of that defense.

B. The Court’s Legal Reasoning

1. Rule 702 vs. Rule 403: Framing the Evidentiary Question

A key conceptual move in the opinion is the Court’s refocusing of the issue from Rule 702 (expert reliability) to Rule 403 (probative value vs. prejudice). The Court recognized that:

• The defense was not trying to introduce scientific polygraph results to prove Eastwood’s guilt or innocence.
• The evidence was offered purely as part of the **narrative context** of interrogation, to support an expert’s psychological theory.

In such a posture:

• There is no need to litigate the general reliability of polygraph testing.
• The jury is not being asked to rely on the polygraph’s accuracy; instead, they are asked to consider what effect being told “you failed” might have on a suspect’s mental state.

Thus, the Court properly located the dispute within Rule 403: is this contextual fact sufficiently probative of the false confession theory, and does that probative value outweigh any risk of confusion or unfair prejudice?

2. Probative Value: The Heart of a False Confession Theory

The Court accepted Hirsch’s theoretical framework:

• False confessions can be “internalized” where a suspect:
  • Is confronted with allegedly objective evidence of guilt, and
  • Already doubts his own memory (due to sleep deprivation, intoxication, or other vulnerabilities).
• Claims that a suspect has “failed” a polygraph are a canonical example of allegedly objective evidence that can trigger such internalization.

Therefore, the fact that:

• Eastwood took a polygraph, and
• Police told him he failed,

is not peripheral—it is a core component of the defense theory. It directly supports Hirsch’s explanation of how an innocent person might come to believe he must have committed the crime and confess accordingly.

By recognizing this close tie between the polygraph evidence and the central contested issue—confession reliability—the Court found substantial probative value under Rule 401/402, making Rule 403’s balancing exercise more exacting.

3. Confusion of the Issues vs. Juror Curiosity

The trial court feared that admitting polygraph-context evidence would confuse the issues by prompting the jury to:

• Speculate about the actual polygraph result, or
• Deliberate about polygraph reliability.

The Supreme Court drew a critical distinction between:

• Curiosity—jurors naturally wondering about unoffered details, and
• Legal confusion—jurors being diverted from the issues they are tasked to decide.

The Court held that:

• Curiosity, standing alone, is not “confusion of the issues” within the meaning of Rule 403.
• The jury could easily have been instructed (under Rule 105) that:
  • They were not to decide the truth or reliability of the polygraph, and
  • They may consider the evidence only for the limited purpose of understanding the circumstances of the confession and the defendant’s mental state.
• Such a limiting instruction would substantially mitigate any risk of confusion while preserving highly probative defense evidence.

This analysis is important beyond the polygraph context. It underscores that trial courts should not equate juror curiosity about collateral matters with genuine risk of confusion sufficient to exclude central defense evidence.

4. Unfair Prejudice: Rejecting a One-Sided View of Polygraph-Related Inferences

The trial court thought the polygraph evidence could unfairly prejudice Eastwood because it might lead jurors to see his confession as strengthened—matching the reasoning in Wright.

The Supreme Court responded by:

• Recognizing that this may sometimes be an inference a juror could draw, but
• Emphasizing that under a modern false confession theory, another reasonable inference is available—that the failed polygraph was one of the pressures causing a false confession.

Because:

• More than one reasonable inference is possible, and
• The evidence was being affirmatively offered by the defense,

the Court found it inappropriate to characterize the polygraph evidence as “unfairly” prejudicial. The defense is generally entitled to take the risk that evidence might cut both ways if it is integral to its theory of the case.

5. The Harmless Error Balancing

The Court’s harmless-error analysis is nuanced. It acknowledges:

• The error was real and involved central defense evidence.
• Yet it simultaneously concludes that the **core of the defense theory** still reached the jury.

Key points in that analysis:

• Hirsch was able to:
  • Explain what an internalized false confession is.
  • Describe both necessary elements (allegedly objective evidence of guilt and memory distrust).
  • Testify that:
    • Eastwood was told by police they believed he was lying, and
    • Eastwood was susceptible due to alcohol use and sleep deprivation.
• Hirsch even gave hypothetical examples of false confessions prompted by alleged failed polygraphs, so the jury could connect those examples to the general fact that police told Eastwood he was lying.
• The only missing detail was that the reason police said he was lying was that he had allegedly failed a polygraph test he had actually taken.

The Court concluded that:

• This missing detail would have made Hirsch’s testimony more vivid and congruent with his examples, but
• Its exclusion did not fundamentally change or cripple the defense theory.

Against that evidentiary background, the Court then weighed other evidence of guilt, including:

• Eastwood’s pre-police-admission to Lauder,
• The physical injuries consistent with a struggle,
• The partial corroboration between the confession and crime-scene details, and
• The circumstantial evidence (DNA under fingernails, space heater suggesting a possible extension cord).

Although the Court candidly admitted the evidence was not “overwhelming,” it held that the limited evidentiary error did not “reasonably” affect the outcome. Thus, reversal was not warranted.

C. Impact on Future Cases and South Carolina Evidence Law

1. Polygraph Evidence as Context vs. Proof

Eastwood draws an important doctrinal line:

• Polygraph results as scientific proof of guilt or innocence remain deeply suspect, likely inadmissible absent stipulation or other special circumstances.
• But evidence that a polygraph was taken and that police told the suspect he failed—offered solely for its effect on the suspect’s mental state and the circumstances of a confession—is a different category of evidence.

In the latter category:

• Rule 702 is generally inapplicable;
• The reliability of polygraph science is not the issue;
• Rule 403 balancing must recognize the substantial probative value to a false confession defense.

This clarification will likely influence how both prosecutors and defense counsel litigate interrogation-context evidence, particularly in confession-heavy cases.

2. Strengthening the Right to Present a Complete Defense

While the Court did not find a constitutional violation, its reasoning strongly resonates with Crane’s emphasis on the defendant’s right to “describe to the jury the circumstances that prompted his confession.”

Going forward, trial courts should be cautious about excluding:

• Evidence surrounding the interrogation process,
• Psychological tactics used (including deceptive claims about evidence, such as failed polygraph allegations), and
• Defendant vulnerabilities (e.g., intoxication, fatigue, mental health issues),

where such evidence is central to a challenge to the reliability of the confession.

3. Limiting Over-Reliance on State v. Wright

By expressly limiting Wright, the Court has made clear that:

• Wright’s skepticism about polygraph-related evidence cannot be read as a blanket prohibition,
• Especially where that evidence is offered by the defense to demonstrate coercion or internalization of false guilt.

Trial courts should now:

• Evaluate each case on its specific facts and theory,
• Recognize that confessions following a “failed” polygraph may be consistent with false confessions, not just with truthful ones.

4. Practical Effects on Trial Practice

For defense counsel:

• False confession defenses are strengthened. Counsel can more confidently seek admission of evidence that the client was told he failed a polygraph (or other “objective” evidence) to support an internalized false confession theory.
• Expert testimony can be better grounded. Experts like Hirsch may now be able to tie their general theories more explicitly to the defendant’s specific experience, including references to supposed polygraph failures, subject to limiting instructions.

For prosecutors:

• The State must anticipate that defense experts will highlight deceptive tactics, including false or misleading references to polygraph results, as a possible cause of false confessions.
• When using such tactics in interrogations, law enforcement and prosecutors must be prepared for those very tactics to be presented to a jury as evidence potentially undermining confession reliability.

For trial judges:

• Courts must perform a more refined Rule 403 analysis, distinguishing between:
  • Evidence offered as scientific proof, and
  • Evidence offered to show the defendant’s psychological environment.
• Limiting instructions under Rule 105 should be considered as a primary tool to reduce risks of confusion, rather than exclusion of core defense evidence.

V. Simplifying Key Legal and Psychological Concepts

A. Internalized False Confession

An “internalized false confession” occurs when a suspect:

• Initially believes he is innocent, but
• Through interrogation tactics and personal vulnerabilities, comes to believe he might actually be guilty, and
• Eventually confesses while sincerely thinking he committed the crime, though in reality he did not.

Two core components:

1. Allegedly objective evidence of guilt: The suspect is told that supposedly reliable, neutral evidence (like DNA, fingerprints, eyewitness identification, surveillance footage, or polygraph results) proves his guilt.
2. Distrust of one’s own memory: Due to factors such as intoxication, sleep deprivation, psychological problems, or suggestive questioning, the suspect begins to doubt his own recollection and to rely instead on the interrogators’ version of events.

In Eastwood, the defense argued that:

• Police telling Eastwood he had failed the polygraph was the “objective evidence,” and
• His alcohol consumption and lack of sleep caused him to distrust his memory, leading to internalization.

B. Rule 403: Probative Value vs. Prejudicial Effect

Rule 403 permits courts to exclude relevant evidence only when its value is substantially outweighed by certain dangers, including:

• Unfair prejudice: The tendency to cause the jury to decide on an improper basis (such as emotion, or misunderstanding),
• Confusion of the issues,
• Misleading the jury,
• Undue delay, or waste of time.

Key ideas:

• Evidence is not “unfairly prejudicial” merely because it is harmful to one side; it must be harmful in some illegitimate or “unfair” way.
• “Confusion of the issues” is not the same as jurors being curious or wanting more information; it refers to a serious risk that jurors will misuse the evidence or focus on the wrong questions.

In Eastwood, the Court concluded that:

• The polygraph-context evidence was highly probative for the defense, and
• Any risk of confusion or prejudice could be controlled by a limiting instruction, not by outright exclusion.

C. Harmless Error

“Harmless error” is a doctrine that says:

• Not every legal mistake at trial requires a new trial.
• An error is harmless if it did not reasonably affect the outcome—i.e., the verdict would almost certainly have been the same even without the error.

In assessing harmlessness, courts look to:

• The importance of the excluded or admitted evidence,
• Whether the same point was established by other evidence,
• The overall strength of the case, and
• How central the issue was to the verdict.

In Eastwood, even though the Court agreed that the trial court erred, it found the error harmless because:

• Hirsch still fully explained the internalized false confession theory and applied it to Eastwood,
• The missing polygraph detail added color but not substance, and
• There was other significant evidence supporting guilt.

D. “Effect on the Listener” vs. Truth of the Matter Asserted

Evidence that someone said “you failed the polygraph” can be offered for two very different purposes:

1. To prove that the person actually failed the polygraph (i.e., as evidence of guilt)—this would raise serious reliability and admissibility questions.
2. To show what effect that statement had on the suspect (e.g., fear, confusion, or pressure that led to a confession)—in this case, the truth or accuracy of the polygraph is irrelevant; what matters is simply that the statement was made.

Eastwood sits squarely in the second category. The defense did not need the polygraph to be accurate; it only needed to show that Eastwood was told he failed, which allegedly contributed to his internalized false confession.

VI. Conclusion: Significance of State v. Eastwood

State v. Eastwood is a nuanced but important opinion at the intersection of confession law, psychological evidence, and evidentiary rules governing polygraphs. Its principal contributions to South Carolina law include:

• Clarifying the admissibility of polygraph-context evidence: When such evidence is offered to illuminate the psychological environment leading to a confession—not to prove the truth of polygraph results—Rule 702’s scientific reliability requirement does not apply. Admissibility instead turns on Rule 403.
• Strengthening the evidentiary basis for false confession defenses: The Court recognizes that allegedly objective evidence of guilt (such as claimed failed polygraphs) is a central component of internalized false confession theory and thus carries substantial probative value.
• Limiting the reach of prior precedent: By cabining State v. Wright to its facts and rejecting its “only inference” approach, the Court aligns South Carolina law with modern understandings of how interrogation tactics can produce false as well as true confessions.
• Reinforcing the right to present a meaningful defense: Although not decided on constitutional grounds, Eastwood echoes Crane v. Kentucky in emphasizing that defendants must be allowed to present the full context of their confessions so juries can fairly assess their reliability.
• Providing a careful model of harmless-error analysis: The Court demonstrates how to recognize and correct an evidentiary misstep while concluding that, in the particular evidentiary landscape of this case, the error did not warrant reversal.

Going forward, Eastwood will guide South Carolina courts in handling polygraph-related evidence and false confession claims. It cautions against reflexive exclusion of interrogation-context evidence and encourages the use of limiting instructions rather than outright bans where the defense seeks to tell a coherent, psychologically grounded story of how a confession came about. At the same time, the decision underscores that even significant evidentiary errors do not automatically mandate a new trial; the ultimate question remains whether the jury’s verdict was fairly reached.