Justia South Carolina Supreme Court Opinion Summaries

James Smith Jr. initiated a civil action against Rufus and Merle Rivers in magistrates court, claiming to be their landlord and seeking their eviction. The Rivers contended that Smith did not own the property where they resided. The magistrates court sided with Smith and ordered the Rivers' eviction. The Rivers appealed, and the circuit court upheld the eviction order. However, the court of appeals reversed the decision, citing a South Carolina Code provision that barred the magistrates court from handling the eviction due to the Rivers' challenge to Smith's property title.The magistrates court initially ruled in favor of Smith, determining that he was the lawful owner and that a landlord-tenant relationship existed. The Rivers filed motions for reconsideration, arguing the court lacked jurisdiction due to a pending circuit court case challenging Smith's ownership. The magistrates court denied these motions, and the Rivers appealed to the circuit court. The circuit court affirmed the magistrates court's decision, finding no evidence to dispute Smith's ownership and confirming the landlord-tenant relationship.The South Carolina Supreme Court reviewed the case and reversed the court of appeals' decision. The Supreme Court held that the magistrates court had the authority to conduct the eviction proceeding because it had determined that a landlord-tenant relationship existed between Smith and the Rivers. The court emphasized that the existence of such a relationship precludes the tenant from challenging the landlord's title in an eviction proceeding. Consequently, the Supreme Court reinstated the magistrates court's eviction order. View "Rivers v. Smith" on Justia Law

Paula Russell, an assistant manager at Wal-Mart, injured her back in 2009 and reached maximum medical improvement in 2011, receiving a seven percent disability rating for her lumbar spine. She was awarded workers' compensation benefits based on this rating. However, her condition worsened, and in December 2011, she sought additional medical treatment and benefits due to a change in her condition. In 2013, a single commissioner found her condition had changed and awarded her continued medical treatment and temporary total disability benefits.The Appellate Panel of the Workers' Compensation Commission reversed this decision, concluding that Russell had not proven her condition had worsened. This led to a series of appeals and remands between the court of appeals, the single commissioner, and the Appellate Panel. In 2019, the South Carolina Supreme Court remanded the case to the Appellate Panel for immediate and final review. The Appellate Panel again found that Russell failed to prove a change of condition, and the court of appeals affirmed this decision.The South Carolina Supreme Court reviewed the case and held that the Appellate Panel's denial of Russell's change of condition claim was not supported by substantial evidence. The court found that the Appellate Panel had improperly weighed the MRI scans over the uncontradicted medical opinions of Russell's doctors, who testified that her condition had worsened. The Supreme Court reversed the decision of the court of appeals and remanded the case to the Workers' Compensation Commission with instructions to award Russell benefits. View "Russell v. Wal-Mart Stores, Inc." on Justia Law

Rashawn Vertez Carter was involved in a violent home invasion and robbery in Aiken, South Carolina, on May 9, 2015. After the crime, law enforcement officers used Carter's real-time cell-site location information from his cell-service provider, T-Mobile, to track him down without obtaining a search warrant. Carter was subsequently arrested and made incriminating statements during interviews with the police.At trial, Carter moved to suppress the evidence obtained from his real-time cell-site location information, arguing that it was obtained in violation of his Fourth Amendment rights and the South Carolina Constitution. The trial court denied the motion, ruling that the information gathered did not constitute a search under either constitution. The jury convicted Carter of burglary, armed robbery, kidnapping, and illegal possession of a weapon, but acquitted him of the alleged sexual assault. Carter appealed to the South Carolina Court of Appeals, which affirmed the trial court's decision, holding that the exigent circumstances exception to the warrant requirement applied and that the good-faith exception to the exclusionary rule also justified the officers' actions.The South Carolina Supreme Court reviewed the case and affirmed Carter's convictions. The court did not address whether a search occurred or if the exigent circumstances exception applied. Instead, it focused on the good-faith exception to the exclusionary rule, concluding that the officers acted in good faith reliance on the federal Stored Communications Act, which allowed the disclosure of customer records in emergencies. The court held that the good-faith exception precluded the suppression of evidence obtained through Carter's real-time cell-site location information, as the officers reasonably believed their actions were lawful under the statute. View "State v. Carter" on Justia Law

In the early morning of March 7, 2015, Robert Xavier Geter and James Lewis engaged in a fight at Culler's Bar in Columbia, South Carolina. The altercation moved outside, where Geter stabbed Lewis, who later died from his injuries. During the incident, Geter also stabbed Clarence Stone, causing permanent blindness in one eye. Geter claimed self-defense, stating he was attacked by multiple people and only used his knife to defend himself.The State indicted Geter for murder and attempted murder, arguing that Geter intended to kill Lewis and that this intent transferred to Stone when he was stabbed. The trial court instructed the jury on the doctrine of transferred intent, and Geter was convicted of both charges. Geter appealed, arguing that transferred intent should not apply to attempted murder and that certain testimony constituted improper bolstering.The South Carolina Court of Appeals reversed Geter's attempted murder conviction, holding that the State needed to prove Geter specifically intended to kill Stone, which was not the State's theory. The court also found that some testimony constituted improper bolstering but deemed it harmless, affirming the murder conviction. Judge Geathers dissented on the transferred intent issue.The South Carolina Supreme Court reviewed the case and held that the doctrine of transferred intent does not apply to attempted murder. The court affirmed the Court of Appeals' decision to reverse Geter's attempted murder conviction and upheld the murder conviction, agreeing that the error in admitting the bolstering testimony was harmless. View "State v. Geter" on Justia Law

In 2001, Frances Mack-Marion refinanced her property, taking out a new mortgage. In 2020, U.S. Bank National Association, the successor-in-interest to the mortgage, initiated foreclosure proceedings against her. Mack-Marion counterclaimed, seeking a declaratory judgment that U.S. Bank was barred from foreclosure because the mortgage closed without attorney supervision, referencing the Matrix Financial Services Corporation v. Frazer decision. The Master-in-Equity dismissed her claim, ruling it lacked subject matter jurisdiction and that the mortgage was recorded before the effective date of Matrix.The Master-in-Equity interpreted Hambrick v. GMAC Mortgage Corporation to mean only the South Carolina Supreme Court could determine unauthorized practice of law claims. Additionally, the Master found Mack-Marion's claim insufficient as the mortgage predated Matrix. Mack-Marion appealed, and the South Carolina Supreme Court granted her motion to certify the appeal.The South Carolina Supreme Court overruled Hambrick to the extent it held that circuit courts lacked subject matter jurisdiction over unauthorized practice of law claims. The Court clarified that circuit courts do have jurisdiction over such claims and reaffirmed that Matrix applies prospectively. The Court held that the Master had subject matter jurisdiction but correctly dismissed Mack-Marion's claim under Rule 12(b)(6), SCRCP, because her mortgage was recorded before the effective date of Matrix. The Court affirmed the Master's dismissal as modified, maintaining that U.S. Bank could pursue foreclosure. View "U.S. Bank National Association v. Mack" on Justia Law

K.S., a minor, through his guardian James Seeger, sued Richland School District Two, alleging gross negligence in supervising K.S.'s first-grade teacher and seeking liability under respondeat superior for injuries K.S. suffered due to the teacher's actions. The teacher, under personal stress, humiliated K.S. and other students, and physically grabbed K.S., causing him pain. K.S. experienced significant emotional distress and was diagnosed with persistent depressive disorder and anxiety.The trial court granted the District a directed verdict, ruling that the District could not be liable for negligence as K.S. suffered no physical injury. The court also excluded Seeger's expert testimony and ruled that the Safe School Climate Act did not repeal the South Carolina Tort Claims Act. The court of appeals affirmed the directed verdict, agreeing that no physical injury occurred and did not address the expert testimony exclusion or the Safe Schools Act ruling.The South Carolina Supreme Court reviewed the case and reversed the directed verdict, finding that the teacher's forceful grabbing of K.S. constituted sufficient physical harm to support a negligence claim. The court also reversed the exclusion of Seeger's expert, Dr. McEvoy, ruling that his testimony was not needlessly cumulative and would have provided crucial insight into the District's policies and their implementation. The court affirmed the trial court's ruling that the Safe Schools Act did not repeal the Tort Claims Act, maintaining that the Act does not create a private right of action or alter tort liability.The Supreme Court remanded the case for further proceedings consistent with its opinion, allowing Seeger's negligence claims to proceed and permitting the District to renew objections to Dr. McEvoy's testimony on remand. View "K.S. v. Richland School District Two" on Justia Law

Jason Edwin Stoots was convicted of second-degree domestic violence following an altercation with his wife, Kimberly, in a Taco Bell drive-thru. Stoots claimed that Kimberly attacked him first, and he accidentally struck her while trying to defend himself. Kimberly testified that Stoots punched her without provocation. The trial court refused to instruct the jury on self-defense and accident, leading to Stoots's conviction.The Circuit Court Judge denied Stoots's request for jury instructions on self-defense and accident, reasoning that Stoots could have left the altercation and that the size difference between him and Kimberly made self-defense inapplicable. The jury was instructed that the State must prove Stoots acted with criminal intent. The jury found Stoots guilty of second-degree domestic violence. Stoots appealed, and the Court of Appeals affirmed the conviction.The Supreme Court of South Carolina reviewed the case and found that the trial court erred in refusing to charge the jury on self-defense. The court held that if there is any evidence from which the jury could reasonably conclude the defendant acted in self-defense, it is reversible error not to instruct the jury on that point. The court disagreed with the State's argument that self-defense was inapplicable due to Stoots's claim of unintentional action. The court also found that the proportionality of Stoots's response to Kimberly's attack was a question for the jury. However, the court found no reversible error in the trial court's refusal to charge the law of accident, as the jury was adequately instructed on the requirement of criminal intent. The Supreme Court reversed the Court of Appeals' decision and remanded the case for a new trial. View "The State v. Stoots" on Justia Law

Innovative Waste Management (IWM) entered into a joint venture with Dunhill Products in 2009 and 2010, which led to allegations of breach of contract, fraud, and misappropriation of trade secrets. IWM accused Dunhill Products, Crest Energy Partners, and Henry Wuertz of stealing trade secrets, interfering with business relationships, and theft of petroleum products. IWM sought $12 million in economic damages and punitive damages. The defendants responded with affirmative defenses and counterclaims. IWM served discovery requests in 2012, but the defendants failed to comply, leading to multiple motions to compel and sanctions.The Circuit Court of Dorchester County found the defendants in contempt for violating discovery orders and sanctioned them by striking their answer and counterclaims. The defendants appealed to the South Carolina Court of Appeals, which affirmed the circuit court's decision in an unpublished opinion. The defendants then sought review by the South Carolina Supreme Court.The South Carolina Supreme Court reviewed whether the Court of Appeals erred in finding that the defendants waived review of the trial court's interlocutory discovery orders and whether the circuit court abused its discretion by striking the defendants' pleadings. The Supreme Court agreed with the Court of Appeals, holding that the defendants waived their right to review the discovery orders by not complying with them and that the circuit court did not abuse its discretion in striking the pleadings due to the defendants' deliberate pattern of discovery abuse. The Supreme Court affirmed the decision of the Court of Appeals. View "Innovative Waste Management, Inc. v. Crest Energy Partners GP, LLC" on Justia Law

Jeane Whitfield filed a medical malpractice lawsuit against Dr. Dennis Schimpf and Sweetgrass Plastic Surgery, LLC, alleging negligence in performing breast augmentation-mastopexy surgery and in post-operative care. Whitfield experienced complications post-surgery, including severe pain and wound issues, leading her to seek further medical attention and additional surgeries. She claimed Schimpf's negligence caused her injuries and inadequate post-operative care exacerbated her condition.The jury in the Circuit Court of Charleston County found in favor of Schimpf and Sweetgrass, determining that Whitfield did not prove the defendants deviated from the standard of care. Whitfield appealed, and the South Carolina Court of Appeals affirmed the trial court's decision. Whitfield then petitioned for a writ of certiorari to the South Carolina Supreme Court, challenging two evidentiary rulings: the exclusion of evidence to show bias of Sweetgrass' office manager, Vicky Tolbert, and the admission of testimony from Schimpf's expert witnesses based on their Rule 35 examinations of Whitfield.The South Carolina Supreme Court found the Court of Appeals correctly affirmed the admission of the expert testimony but erred in affirming the exclusion of evidence of Tolbert's bias. The Supreme Court held that evidence of Tolbert's sexual relationship with Schimpf, her salary, and the free cosmetic procedures she received was relevant to show potential bias and should have been admitted. The Court determined that excluding this evidence was prejudicial to Whitfield's case, as it impacted the jury's ability to assess Tolbert's credibility. Consequently, the Supreme Court reversed the Court of Appeals' decision and remanded the case for a new trial. View "Whitfield v. Schimpf" on Justia Law

Therese Hood was involved in a three-car accident and subsequently filed multiple lawsuits. Hood's underinsured motorist (UIM) carrier, United Services Automobile Association (USAA), provided her with counsel in a lawsuit filed by the Kucks, who were also involved in the accident. Hood also sued Johnson, the driver who initially hit her, and USAA defended Johnson under Hood's UIM policy. During mediation, USAA offered $200,000, but Hood did not accept it, and the case went to trial, where Hood won. Hood then filed a third lawsuit against USAA, alleging bad faith, negligence, and other claims, arguing that USAA took disparate positions on her headlight use and did not offer its full settlement authority during mediation.The Circuit Court granted summary judgment for USAA on several claims and directed a verdict on others, leaving only the bad faith and negligence claims for the jury. The jury found in favor of USAA on the bad faith claim but in favor of Hood on the negligence claim, awarding her damages. The trial court granted USAA's motion for judgment notwithstanding the verdict (JNOV) on the negligence claim, stating that a first-party insured could only bring a bad faith claim, not a negligence claim. The Court of Appeals affirmed this decision, holding that a first-party insured has no separate cause of action in negligence under the duty of good faith and fair dealing.The South Carolina Supreme Court reviewed the case and affirmed the Court of Appeals' decision. The court held that South Carolina law does not recognize a separate negligence claim between an insured and insurer, only a bad faith claim. The court also found that USAA did not act in bad faith during mediation or by taking a position on Hood's headlight use in the UIM action. The court concluded that USAA's actions were within its rights and that Hood's claims were without merit. View "Hood v. USAA" on Justia Law