Justia South Carolina Supreme Court Opinion Summaries

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

The case involves a challenge to the constitutionality of the 2023 Act No. 8 (S. 39), known as the Education Scholarship Trust Fund (ESTF) Act, which establishes a fund to provide scholarships for qualifying educational expenses, including private school tuition. Petitioners argue that the Act violates South Carolina's constitutional prohibition against using public funds for the direct benefit of private educational institutions.The lower courts did not review this case; it was accepted directly by the South Carolina Supreme Court in its original jurisdiction. Petitioners sought an injunction and declaratory judgment, claiming the Act violated several provisions of the South Carolina Constitution, including Article XI, Sections 2, 3, and 4, and Article X, Sections 5 and 11.The South Carolina Supreme Court held that portions of the Act violate the state constitution's prohibition against using public funds for the direct benefit of private educational institutions. The court found that the ESTF funds are public funds and that using these funds for private school tuition constitutes a direct benefit to private educational institutions, which is unconstitutional under Article XI, Section 4. The court severed and declared unconstitutional the provisions of the Act that allowed payments from ESTF scholarships for tuition and fees at private educational institutions. The court enjoined the Department of Education from disbursing ESTF scholarships for these purposes. The court's decision was guided by the principle that legislative policy must conform to constitutional mandates, and it emphasized the importance of adhering to the plain meaning of constitutional text. View "Candace Eidson v. South Carolina Dept. of Education" on Justia Law

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

The South Carolina Supreme Court granted petitioners' request for a declaration with respect to Provisos 1.108 and 1.103 of the 2021-2022 Appropriations Act1 were invalid. Proviso 1.108 (enacted June 22, 2021,) was directed to the South Carolina Department of Education for South Carolina's kindergarten through 12th grade (K-12) public schools, and banned face mask mandates at any of its education facilities. Proviso 1.103 permitted school districts to offer a virtual education program for up to five percent of its student population based on the most recent 135 day ADM [(average daily membership)]count without impacting any state funding. For every student participating in the virtual program above the five percent threshold, the school district would not receive 47.22% of the State per pupil funding provided to that district as reported in the latest Revenue and Fiscal Affairs revenue per pupil report pursuant to Proviso 1.3. Although the School District did not require its students to wear masks in its education facilities, it claimed Proviso 1.108 conflicted with local laws regarding mask requirements in schools and placed the School District in an untenable position. In addition, Petitioners claimed the School District reached the five percent cap for virtual enrollment and did not wish to risk losing state funds by exceeding the cap in Proviso 1.103. The School District asked for guidance on its options and obligations regarding face masks and virtual education. Petitioners contended: (1) Provisos 1.108 and 1.103 violate the one-subject rule of article III, section 17 of the South Carolina Constitution; (2) the plain language of Proviso 1.108 permitted the School District to implement and enforce mask mandates in its education facilities if the School District did so with funds not appropriated or authorized in the 2021-2022 Appropriations Act; (3) Provisos 1.108 and 1.103 improperly invade the authority of local school boards; and (4) Provisos 1.108 and 1.103 denied equal protection to students and violated their constitutional right to free public education. The Supreme Court held the provisos were constitutional, and rejected the remaining challenges to the validity of the provisos. View "Richland County School District 2 v. Lucas" on Justia Law

South Carolina Attorney General Alan Wilson sought a declaration by the South Carolina Supreme Court concerning the use of facemasks in the public schools of South Carolina during the coronavirus pandemic. The Court construed Proviso 117.190 of the 2021-2022 Appropriations Act relating to public institutions of higher learning, and determined from the language in that proviso that the University of South Carolina was not precluded from issuing a universal mask mandate that applied equally to vaccinated and unvaccinated students and faculty alike. This case involved a different proviso from the 2021-2022 Appropriations Act: Proviso 1.108, relating to public schools serving students grades kindergarten through 12 (K-12). Proviso 1.108 manifestly set forth the intent of the legislature to prohibit mask mandates funded by the 2021-2022 Appropriations Act in K-12 public schools. The Attorney General contended the City of Columbia passed ordinances in direct opposition to Proviso 1.108, mandating masks in all K-12 public schools in the City of Columbia. "While allowing school districts flexibility to encourage one policy or the other, the state legislature has elected to leave the ultimate decision to parents. Conversely, the City of Columbia has attempted to mandate masks for all school children by following guidance from the Centers for Disease Control, which has the effect of disallowing parents a say in the matter." The Supreme Court upheld Proviso 1.108 and declared void the challenged ordinances of the City of Columbia insofar as they purported to impose a mask mandate in K-12 public schools. View "Wilson v. City of Columbia" on Justia Law

The issue presented in this declaratory action before the South Carolina Supreme Court in its original jurisdiction was a challenge to the constitutionality of Governor Henry McMaster's allocation of $32 million in federal emergency education funding for the creation of the Safe Access to Flexible Education ("SAFE") Grants Program. Petitioners contended the program violated South Carolina's constitutional mandate prohibiting public funding of private schools. The Supreme Court held the Governor's decision constituted the use of public funds for the direct benefit of private educational institutions within the meaning of, and prohibited by, Article XI, Section 4 of the South Carolina Constitution. "Even in the midst of a pandemic, our State Constitution remains a constant, and the current circumstances cannot dictate our decision. Rather, no matter the circumstances, the Court has a responsibility to uphold the Constitution." View "Adams v. McMaster" on Justia Law

Melissa Spalt was arrested for driving under the influence of alcohol. When she refused to submit to a breath test, the arresting officer issued a "notice of suspension" of her driver's license. Spalt requested a hearing before the South Carolina Office of Motor Vehicle Hearings (OMVH) to challenge her suspension, as permitted by subsection 56-5-2951(B)(2). The OMVH scheduled a hearing for June 23, 2015, at 9:00 a.m. On June 18, Spalt's attorney notified the OMVH he was scheduled to be in court at the time of the new OMVH hearing. Spalt's attorney emailed the agency and hearing officer multiple times to reschedule the hearing; there was no indication in the record that the OMVH hearing officer responded to the attorney's last emails. At the time of the hearing, Spalt's attorney did not appear. The hearing officer entered an "Order of Dismissal", finding "Neither [Spalt] nor her counsel appeared at the hearing and therefore waived the right to challenge the pending suspension." The hearing officer did not conduct a hearing on the merits of the suspension. Spalt appealed to the ALC, which reversed and remanded to the OMVH for a hearing on the merits. The Department of Motor Vehicles appealed the ALC's order to the court of appeals, which dismissed the appeal on the basis the ALC's order was not immediately appealable. The Department appealed again to the South Carolina Supreme Court, but finding no error, the Supreme Court affirmed the court of appeals. View "Spalt v. South Carolina Dept. Motor Vehicles" on Justia Law

The plaintiffs, including eight South Carolina school districts, claimed that the State has failed to meet the constitutional obligation that there be a system of free public schools that affords each student the opportunity to receive a minimally adequate education. The trial court held that the State's failure to address the effects of pervasive poverty on students within the plaintiffs' school districts prevented those students from receiving the required opportunity. The trial court performed a "thorough and cogent examination" of the issues of this case. While the South Carolina Supreme Court agreed with the trial court's conclusion regarding the adverse effects of poverty, the Record demonstrated that there were myriad other issues, under the State's control, working to prevent students within these districts from receiving the constitutionally required opportunity. Thus, the Court found in favor of the plaintiffs, and affirmed as modified. View "Abbeville County School District v. South Carolina" on Justia Law

For about forty years, 100 and 200 children residing in the Mitford Community of Fairfield County have been attending Chester County School District (CCSD) schools in the Great Falls area of Chester County. The CCSD schools are closer to the Mitford Community than are any Fairfield County School District (FCSD) schools. The Mitford students have been attending CCSD schools at no cost to the students or their families. Mitford students' attendance at CCSD schools began as a result of a Federal 1970 desegregation order, which required the all African-American Mitford Elementary School be closed, and its students be given the choice of attending CCSD's Great Falls schools. The General Assembly passed Act No. 1236, consolidating the Mitford Community into CCSD. This Act was repealed the following year based on an agreement between FCSD and CCSD respecting the Mitford Community's students' enrollment in CCSD's schools. Under this agreement, FCSD paid CCSD $25,000 per year for educational expenses. This agreement ended in the 2009-10 school year when no agreement was reached for that year or thereafter. In light of the school districts' failure to reach an agreement for payment to CCSD for the cost of educating Mitford Community's students in CCSD's schools and FCSD's refusal to continue negotiations, the General Assembly passed Act No. 294 of 2010 in order to provide for a uniform arrangement between FCSD and CCSD. Pursuant to section 59-63-485(C), CCSD has invoiced the Fairfield County Treasurer for the expenses of educating the Mitford children for the past three school years. FCSD filed suit against the Respondents seeking a declaratory judgment that Act No. 294 was unconstitutional. CCSD, the State, and FCSD filed cross motions for summary judgment as to the constitutionality of Act No. 294. The circuit court issued an order denying FCSD's motion and granting CCSD and the State's motions for summary judgment, holding that Act No. 294 was constitutional special legislation, and FCSD appealed. In a direct appeal to the Supreme Court, the Board of Trustees for the FCSD appealed the circuit court's grant of summary judgment in favor of the State, CCSD, the Fairfield County Treasurer, and the State Department of Education. Finding no reversible error, the Supreme Court affirmed. View "Board of Trustees for the Fairfield County School District v. South Carolina" on Justia Law

Appellants appealed the grant of summary judgment in favor of the respondents in this case. The case was dismissed after respondents moved for judgment on the pleadings under Rule 12(c), SCRCP. Because the Supreme Court found issues of fact raised by the complaint that needed to be resolved before the constitutionality of 2009 Act No. 99 could be determined, the case was reversed and remanded for further proceedings. "The circuit court and respondents [relied] on a single sentence found in 'Bradley v. Cherokee School Dist. No. One,' [470 S.E.2d 570 (1996)]: A law that is special only in the sense that it imposes a lawful tax limited in application and incidence to persons or property within a certain school district does not contravene the provisions of Article III, section 34(IX)." In this case, the Supreme Court held that Appellant's complaint centered on an impact fee, not a tax, and one that is placed on only some persons and not others. Moreover, since 'Bradley' was decided, the Court clarified that all challenges to education-related special legislation were subject to the test set forth in 'Kizer v. Clark,'(600 S.E.2d 529 (2004)). The Supreme Court found that appellants' complaint alleged facts which, if resolved in their favor, would result in a declaration that the Act is unconstitutional. The order granting respondents' Rule 12(c) motion was therefore reversed.View "Home Builders Association v. School District No. 2 of Dorchester County" on Justia Law