Justia South Carolina Supreme Court Opinion Summaries
State v. Grissett
In South Carolina, the case revolves around the interpretation of a law concerning the calculation of the one-year maximum Community Supervision Program (CSP) revocation sentence. The key question is whether inmates arrested for alleged CSP violations should receive credit towards their potential CSP revocation sentence for the time they spent in jail awaiting the adjudication of the CSP violation charge. The Petitioner, Stacardo Grissett, violated the terms of his CSP and was denied credit for roughly six months he spent in jail awaiting his CSP revocation hearing. His appeal was dismissed as moot because he had completed his CSP revocation sentence and original sentence by the time it reached the Court of Appeals. The Supreme Court of South Carolina, however, chose to review the case due to its potential for repetition and the need for clarification. The court ruled that inmates must be given credit for any time served awaiting their CSP revocation hearing towards their CSP revocation sentence. The court's decision hinged on the interpretation of Section 24-21-560(C), which states that an inmate who is incarcerated for a CSP violation is not eligible to earn credits that would reduce the sentence. The court held that time served does not "reduce" a sentence, but only affects the date on which the sentence begins, thereby ruling in favor of the Petitioner. View "State v. Grissett" on Justia Law
Posted in:
Criminal Law, Government & Administrative Law
Rice v. Doe
In this case, the South Carolina Supreme Court was asked to decide whether the requirement for a witness affidavit under subsection 38-77-170(2) of the South Carolina Code should be considered a condition precedent to filing a "John Doe" civil action. The case arose from a car accident where the plaintiff, Peter Rice, filed a lawsuit against an unidentified driver, referred to as "John Doe." Rice alleged that Doe's vehicle crossed into his friend's lane, causing his friend to swerve and hit a tree. Under South Carolina law, it's possible to recover damages under an uninsured motorist policy for accidents caused by unidentified drivers. However, the law requires that the accident must have been witnessed by someone other than the owner or operator of the insured vehicle and that the witness must sign an affidavit attesting to the truth of the facts of the accident. Doe moved to dismiss the case on the grounds that Rice had failed to comply with the requirement for a witness affidavit at the time of filing his complaint. The lower court initially denied Doe's motion, but later another judge ruled that the affidavit was a condition precedent to the right to bring an action and dismissed the case. The court of appeals reversed this decision, finding that the second judge did not have the authority to overrule the first judge's decision. On review, the South Carolina Supreme Court held that compliance with the witness affidavit requirement is not a condition precedent to filing a "John Doe" civil action. Rather, the court found that the witness affidavit may be produced after the commencement of the lawsuit. However, the court noted that the affidavit should be produced promptly upon request and if it is not, the action could be dismissed pursuant to Rule 56(c) of the South Carolina Rules of Civil Procedure. The Supreme Court therefore affirmed the decision of the court of appeals, albeit on different grounds, and remanded the case for trial. View "Rice v. Doe" on Justia Law
Walterboro Comm Hospital v. SCDHEC
In South Carolina, two hospitals, Walterboro Community Hospital and Trident Medical Center, appealed an Administrative Law Court (ALC) order which approved the certificate of need (CON) for the Medical University Hospital Authority (MUHA). MUHA had applied for a CON to construct a new general hospital in Berkeley County to address capacity issues at its existing hospital in Charleston. The appellant hospitals raised four issues against ALC's decision: 1) the ALC's dismissal of certain errors in the review by the South Carolina Department of Health and Environmental Control (DHEC), 2) a misinterpretation of the State Health Plan by the ALC, 3) the ALC's approval of MUHA's application conditional on the closure of a freestanding emergency department planned by MUHA, and 4) the appeal bond required by South Carolina law is unconstitutional.The Supreme Court of South Carolina affirmed the ALC's decision and held that despite errors in DHEC's review process and decision, the ALC's de novo review rendered these errors harmless. The court also agreed with ALC's interpretation of the State Health Plan and found no issue in the ALC's condition of approval. The court further held that the appeal bond requirement was not unconstitutional, as the appellant hospitals were statutory affected persons and there was a rational basis for different treatment for a party opposing an approved CON and a party appealing the denial of its own CON application. However, the court did instruct that the appeal bond be voided and returned to Trident Medical Center. View "Walterboro Comm Hospital v. SCDHEC" on Justia Law
State v. William C.Sellers
In South Carolina, a defendant, William C. Sellers, was convicted of murder in connection with the killing of Johnny Hydrick. The State presented evidence that Sellers personally murdered Hydrick during a burglary and robbery attempt to steal Oxycodone, guns, and cash from Hydrick's home. The State also presented an alternative theory that Sellers was guilty under the doctrine of "the hand of one is the hand of all" because he and another man agreed to carry out the burglary and robbery, during which one or both of them fatally beat Hydrick.The Supreme Court of South Carolina affirmed the lower court's decision. The court addressed two main issues. First, it considered whether the trial court's jury instruction defining malice partly as "the intentional doing of a wrongful act without just cause or excuse" improperly shifted the burden of proof to Sellers. The court found that the instruction did not shift the burden because the State was required to prove beyond a reasonable doubt that Sellers acted "without just cause or excuse."Second, the court examined whether the State presented sufficient evidence to support instructing the jury on Sellers' criminal liability under the doctrine of "the hand of one is the hand of all." The court found that the State had presented evidence that Sellers and another man had agreed to commit the burglary and robbery, and that both had beaten Hydrick during the course of these crimes. Thus, the instruction was supported by the evidence.Therefore, the court affirmed Sellers' conviction for murder. View "State v. William C.Sellers" on Justia Law
Posted in:
Criminal Law
Hughes v. Bank of America
In South Carolina, Phillip Francis Luke Hughes, on behalf of the estate of his late mother, Jane Hughes, sued Bank of America for fraud, fraudulent concealment, and breach of contract, alleging that the bank charged insurance premiums in connection with a home equity line of credit his parents obtained in 2006, even though they declined the insurance offer. The bank argued that the claims did not survive Jane Hughes's death, were barred by res judicata and the statute of limitations, and that their motion for sanctions was not premature.The Supreme Court of South Carolina held that the claims for fraud and fraudulent concealment survived Jane Hughes's death. However, it also held that all three claims were barred by the res judicata effect of rulings in related federal court litigation. The court affirmed as modified in part and reversed in part the lower court's decision. The court also affirmed the lower court's decision that the sanctions motion was not premature. The court further held that the claim for breach of contract accompanied by a fraudulent act survived Jane Hughes's death, but was also barred by res judicata.As for the statute of limitations issue, the court held that the statute of limitations had expired before the action was commenced and that the plaintiff was precluded from relitigating the equitable tolling issue. The court remanded Bank of America's sanctions motion to the lower court for disposition. View "Hughes v. Bank of America" on Justia Law
Cruce v. Berkeley County School Dist
In this case, Jeffrey L. Cruce, the former head football coach and athletic director for Berkeley High School, filed a lawsuit against the Berkeley County School District (the District) for wrongful termination and defamation. The defamation claim was based on an email circulated by an athletic trainer questioning the integrity of student athlete files maintained by Cruce. The court of appeals had ruled that Cruce was a public official for the purposes of defamation law, and thus required to prove actual malice to win his defamation claim, which the South Carolina Tort Claims Act (SCTCA) grants the District immunity from.The Supreme Court of South Carolina disagreed, stating that being a public employee and enjoying media attention does not make Cruce a public official, as he did not have any official influence or decision-making authority about serious issues of public policy or core government functions. The court also rejected the District's claim that Cruce was a public figure, stating that the controversy over Cruce's coaching tactics did not affect large segments of society and was unrelated to the defamation claim. The court ruled that Cruce was not a public official, not a public figure, and that his defamation claim was supported by evidence, reversing the decision of the court of appeals and reinstating the jury's damages award. View "Cruce v. Berkeley County School Dist" on Justia Law
State v. Benton
The Supreme Court of South Carolina affirmed the decision by the court of appeals in the case of Tommy Lee Benton, who was convicted for the murder of Charles Bryant Smith, two counts of first-degree burglary, one count of first-degree arson, and one count of third-degree arson. Benton's first trial was declared a mistrial due to his failure to disclose his alibi, which he intended to support via his great-grandmother's testimony. Benton claimed that his second trial and ensuing convictions were barred by double jeopardy. The court, however, found that the mistrial was declared due to "manifest necessity," hence, there was no double jeopardy violation.Benton also argued against the admissibility of gruesome crime scene photographs and certain text and Facebook messages. The court upheld the trial court's decision, asserting that the photographs provided important context to the testimony and other key evidence. The court noted that while the photographs were disturbing, any error in admitting them was harmless as they did not significantly contribute to the verdict. The court also affirmed the admissibility of the text and social media messages. View "State v. Benton" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Applied Building Sciences v. SC Dept of Commerce
In this case, the South Carolina Supreme Court upheld the constitutionality of a state statute that limits reimbursement of reestablishment expenses in condemnation proceedings to $50,000. The appellant, Applied Building Sciences, Inc., an engineering firm, was forced to move its operations when its leased building was condemned for public use by the South Carolina Department of Commerce, Division of Public Railways. The company sought reimbursement for reestablishment expenses exceeding $560,000 but was limited by state statute to $50,000. The company argued that the cap was unconstitutional under the Takings Clauses of the South Carolina and United States Constitutions. The court found that reestablishment expenses are separate from damages awardable as just compensation under both constitutions, thus upholding the constitutionality of the statutory cap. The court affirmed the lower court's granting of summary judgment in favor of the Department of Commerce, Division of Public Railways. View "Applied Building Sciences v. SC Dept of Commerce" on Justia Law
South Carolina v. Heyward
James Heyward was convicted of multiple crimes arising from the armed robbery, brutal beating, and murder of Alice Tollison during the burglary of her home. The South Carolina Supreme Court granted Heyward's petition for a writ of certiorari to address the trial court's refusal to remove Heyward's leg shackles during the striking of the jury, and four evidentiary issues. As to three of the evidentiary issues, the authentication of a fingerprint card, the admission of gruesome autopsy photographs, and the State's use of Heyward's alias, the Supreme Court found the trial court acted within its discretion. As to the other evidentiary issue, a firearms expert's testimony Heyward's pistol was operational at the time of the crimes, the Supreme Court affirmed the court of appeals' ruling that if there was any error in the admission of that testimony it did not prejudice Heyward. As to the leg shackles, the Court found the trial court erred in failing to exercise its discretion in determining whether Heyward should have been required to wear leg shackles in the presence of the jury. However, because the State conclusively proved Heyward's guilt through overwhelming evidence such that no rational conclusion could have been reached other than Heyward is guilty of these crimes, the Court nevertheless affirmed. View "South Carolina v. Heyward" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Estate of Jane Doe 202 v. City of North Charleston
This appeal arose from a defense verdict in a case alleging law enforcement officers and the City of North Charleston violated the civil rights of Jane Doe, a vulnerable adult. During its deliberations, the jury submitted several questions, the last of which was ambiguous. The trial court answered the question without requesting clarification from the jury and denied Doe's request to charge the jury on nominal damages for a third time. The court of appeals affirmed. The South Carolina Supreme Court found the trial court erred in not requesting clarification, but ultimately concluded the error was harmless. The Court therefore affirmed the court of appeals in result. View "Estate of Jane Doe 202 v. City of North Charleston" on Justia Law
Posted in:
Civil Procedure, Personal Injury