Justia South Carolina Supreme Court Opinion Summaries

Respondent Braden's Folly, LLC owned two small, contiguous, developed coastal properties on the northeast end of Folly Beach, South Carolina. The City of Folly Beach amended an ordinance to require certain contiguous properties under common ownership to be merged into a single, larger property. The ordinance did not impact the existing uses of Braden's Folly's contiguous lots. Nevertheless, Braden's Folly challenged the merger ordinance, claiming it had planned to sell one of the developed properties, and that the merger ordinance interfered with its investment-backed expectation under the test announced in Penn Cent. Transp. Co. v. City of N.Y., 438 U.S. 104, 124 (1978). Folly Beach denied the claim of an unconstitutional regulatory taking. Pursuant to cross-motions for summary judgment, the circuit court agreed with Braden's Folly, finding the merger ordinance effected an as-applied taking of Braden's Folly's beachfront property. Folly Beach appealed the judgment in favor of Braden's Folly. Underlying the South Carolina Supreme Court's application of the Penn Central factors was the "distinct fragility" of Folly Beach's coastline, which was subject to such extreme erosion that the General Assembly exempted Folly Beach from parts of the South Carolina Beachfront Management Act. This exemption gave the city the authority to act in the State's stead in protecting the beach there. One of Braden's Folly's properties was contributing to worsening erosion rates on Folly Beach and, along with similarly situated properties, was threatening the existence of the entire beach in that area of the state. The Court concluded Braden's Folly had not suffered a taking under the Penn Central test. Therefore, the judgment was reversed and the case remanded for entry of judgment in favor of Folly Beach. View "Braden's Folly, LLC v. City of Folly Beach" on Justia Law

Petitioner Quincy Allen, a formerly death-sentenced inmate housed at Broad River Correctional Institution, appealed to the Administrative Law Court (ALC) the denial by the South Carolina Department of Corrections (SCDC) of his grievance concerning visitation with persons not known to him prior to his incarceration. Following the ALC's dismissal of Petitioner's appeal, Petitioner appealed to the court of appeals. The court of appeals affirmed the order of the ALC. Petitioner now sought certiorari review by the South Carolina Supreme Court. The Supreme Court granted the petition, dispensed with briefing, and affirmed the decision of the court of appeals as modified. The Court determined the court of appeals incorrectly analyzed the issue as one of "subject matter jurisdiction" when it affirmed the ALC's decision. However, the Supreme Court affirmed the holding that the denial of Petitioner's visitation with persons not known to him prior to incarceration did not implicate a state-created liberty interest, and the Supreme Court agreed with the result of the court of appeals' decision to affirm the dismissal of Petitioner's appeal by the ALC. View "Allen v. SCDC" on Justia Law

Appellant Timothy Jones, Jr. admitted to killing his five young children and was indicted for five counts of murder. He was convicted by jury and sentenced to death. In a direct appeal to the South Carolina Supreme Court, Jones raised eight issues centering on three points: juror qualification, requested voir dire and a related jury instruction, and evidentiary rulings made during the guilt and sentencing phases. After review, the Supreme Court affirmed the juror qualification, voir dire, and jury instruction rulings. The Court held the trial court erred in certain evidentiary rulings; however, the Court found the errors were harmless and affirmed Jones's conviction and death sentence. View "South Carolina v. Jones" on Justia Law

At Stewart Middleton's trial for third-degree criminal sexual conduct, the State introduced a police detective's testimony that Middleton was evasive in response to her attempts to get Middleton to come in for an interview. The trial court admitted this testimony over Middleton's relevance objection. The jury found Middleton guilty and the court of appeals affirmed. The South Carolina Supreme Court held that the trial court erred in finding the testimony relevant because the State did not establish a nexus between Middleton's conduct and a consciousness of his guilt. The conviction was reversed and the case remanded for a new trial. View "South Carolina v. Middleton" on Justia Law

Craig Busse appealed his conviction for second-degree criminal sexual conduct with a minor, claiming the deputy solicitor improperly vouched for the victim's credibility in a statement he made during closing argument. The court of appeals affirmed. The South Carolina Supreme Court found the deputy solicitor's statement was technically in error and the trial court should have sustained Busse's objection. However, the statement did not amount to vouching. Therefore, the Supreme Court found no reversible error and affirmed. View "South Carolina v. Busse" on Justia Law

Four prisoners filed a declaratory judgment action challenging two of the execution methods set forth in South Carolina's death penalty statute: electrocution and firing squad. The prisoners contend the methods violate the South Carolina Constitution's article I, section 15 prohibition against cruel, corporal, or unusual punishment. The circuit court concluded electrocution and the firing squad were unconstitutional under state law, and the parties filed cross-appeals with the South Carolina Supreme Court. The primary appeal concerned the merits of the ruling, and the prisoners' cross-appeal challenged the partial denial of their pretrial discovery request for information on the availability of a third statutory method of execution, lethal injection. At this time, the Supreme Court reversed the circuit court's discovery ruling (which was the subject of the cross-appeal), and remanded the discovery issue to the circuit court for further proceedings to be completed in accordance with time limits set forth in this opinion. The Supreme Court held the remainder of the appeal in abeyance pending the circuit court's resolution of the discovery issue. View "Owens, et al. v. Stirling, et al." on Justia Law

Respondent Maunwell Ervin was granted post-conviction relief (PCR) for being twice tried for multiple offenses stemming from a search if his rented residence. Ervin was charged on firearms and drug trafficking charges; the first trial ended in an acquittal of the firearm charge, and a mistrial on the trafficking charge. The second trial resulted in another mistrial on the trafficking charge. Ervin and the State reached a plea agreement by reducing the charge to a lesser offense and imposing the minimum sentence. Ervin then applied for PCR on the negotiated plea. The PCR court granted relief on Ervin’s claim of ineffective assistance of counsel, premised on counsel’s failure to raise a double jeopardy objection based on the rule established in Yeager v. United States, 557 U.S. 110(2009). The South Carolina Supreme Court determined the PCR court misapplied Yeager, thereby erring in granting PCR relief. Accordingly, relief was reversed and the negotiated guilty plea and sentence were reinstated. View "Ervin v. South Carolina" on Justia Law

In 2021, the South Carolina General Assembly passed the Fetal Heartbeat and Protection from Abortion Act ("the Act"), which prohibited an abortion after around six weeks gestation. This was before many women—excluding those who were trying to become pregnant and were therefore closely monitoring their menstrual cycles—even know they were pregnant. The Supreme Court held that the decision to terminate a pregnancy rested upon the "utmost personal and private considerations imaginable," and implicates a woman's right to privacy. "While this right is not absolute, and must be balanced against the State's interest in protecting unborn life, this Act, which severely limits—and in many instances completely forecloses—abortion, is an unreasonable restriction upon a woman's right to privacy and is therefore unconstitutional." View "Planned Parenthood South Atlantic, et al. v. South Carolina, et al." on Justia Law

Jaron Gibbs was convicted of murder and possession of a weapon during the commission of a violent crime. He appealed, arguing the trial court erred in (1) allowing Detective Michael Arflin to present lay testimony about single and double action revolvers and (2) allowing the State to reference Arflin's testimony in its closing argument. The court of appeals affirmed Gibbs's convictions. The South Carolina Supreme Court found that because the court of appeals held Arflin's personal knowledge rendered the lay testimony proper, it did not squarely address whether the trial court erred in finding this subject matter was not outside the ordinary knowledge of most jurors. In any event, the Court determined the trial court did not abuse its discretion in finding the testimony did not have to be given by an expert. The Court therefore affirmed the court of appeals as modified and hedld the trial court did not err in admitting Arflin's lay testimony. Likewise, the Court found the solicitor's closing was "certainly proper" when viewed as a reply to Gibbs's theory of the case. "Under the invited reply doctrine, conduct that would be improper otherwise may be appropriate if made in response to statements or arguments made by the defense." The Supreme Court affirmed the court of appeals' analysis and held the trial court did not err with respect to the solicitor's closing argument. View "South Carolina v. Gibbs" on Justia Law

Angela Brewer was convicted of homicide by child abuse after her thirteen-month-old grandson died from drinking lemonade mixed with oxycodone. Brewer contended the court of appeals erred in upholding the trial court's admission of an interrogation video when she was under the influence of medication. She also raised an issue relating to the scope of the Sixth Amendment's Confrontation Clause when the State sought to introduce the contents of a toxicology report from an out-of-state laboratory through a pathologist who did not perform the actual testing. The trial court concluded the toxicology report was not testimonial in nature, thereby removing it from the confines of the Sixth Amendment, and the court of appeals affirmed. While the South Carolina Supreme Court saw no error in admitting the interrogation video, it reversed Brewer's conviction and sentence based on a Confrontation Clause violation: "the Confrontation Clause mandates that an individual who actually performed the forensic testing be subject to cross- examination." View "South Carolina v. Brewer" on Justia Law