Code confirms these guarantees by allowing criminal defendants to compel witnesses to appear in their favor and to produce witnesses and evidence at trial. See S.C.Code Ann. § 17-23-60 (1976); S.C.Code Ann. § 19-7-60 (1976). These safeguards ensure the accused will benefit from a fair and impartial trial. “Few rights are more fundamental than that of an accused to present witnesses in his own defense.” Chambers v. Mississippi, 410 U.S. 284, 302, 93 S.Ct. 1038, 35 L.Ed.2d 297 (1973); see also California v. Trombetta, 467 U.S. 479, 485, 104 S.Ct. 2528, 81 L.Ed.2d 413 (1984) (finding the Due Process Clause of the Fourteenth Amendment affords criminal defendants a meaningful opportunity to present a complete defense); State v. Hutton, 358 S.C. 622, 631, 595 S.E.2d 876, 881 (Ct.App.2004) (<HOLDING>); State v. Harris, 311 S.C. 162, 167, 427
holding that the constitution guarantees criminal defendants a meaningful opportunity to present a complete defense  recognizing fundamental fairness requires criminal defendants be granted a meaningful opportunity to present a complete defense recognizing a criminal defendants right to present a complete defense holding that constitution requires  an opportunity  granted at a meaningful time and a meaningful manner  for a hearing appropriate to the nature of the case holding that fundamental fairness demands at least an opportunity to present rebuttal to surprise evidence