State v. Mitchell, 840 S.E.2d 276 (2020)

Rule 701 allows a non-expert to testify in the form of opinion or inference where it is rationally based on a perception of the witness and helpful to the determination of a fact in issue. Testimony from a lay witness and an officer about their suspicion that the defendant used an app to conceal text messages and regarding record keeping of those messages was an error, but not plain error.