Justia South Carolina Supreme Court Opinion Summaries

Appellant Martha Argoe's husband had her committed to Three Rivers Behavioral Health, LLC (Three Rivers). In June 2005, the probate court accepted the petition, and issued an order to have Mrs. Argoe involuntarily committed to the hospital and examined by licensed physicians. Physicians determined that Mrs. Agroe suffered from bipolar disorder with manic and psychotic features. Mrs. Argoe submitted to additional tests, and was prescribed medication as part of her therapy. In June 2007, Mrs. Argoe sued her husband, son and the hospitals, physicians and nurses who were involved in the involuntary commitment proceedings. She asserted multiple causes of action, including "intentional infliction of emotional distress," false imprisonment, conspiracy, defamation, and invasion of privacy. Three Rivers moved for summary judgment, arguing among other things, that Mrs. Argoe's claims should have been brought in 2005 when the original commitment order was issued. On appeal to the Supreme Court, Mrs. Argoe argued that the probate court's order was invalid. Upon careful consideration of the arguments and the applicable legal authority, the Supreme Court found that Mrs. Argoe failed to timely and properly challenge the 2005 probate court orders, and that Three Rivers' conduct toward her was lawful, justified and reasonable. The Court affirmed the probate court's order.

In March 2000, Theodora Miles sought a divorce from James Miles. Prior to the final hearing, the parties reached an agreement on many issues pertaining to the division of the marital property, health insurance, child support and custody. Six years later, Mr. Miles sought to modify the settlement agreement due to a "substantial change in circumstances." In particular, Mr. Miles sought a reduction in his child support payments, and to stop paying for his ex-wife's health insurance. The issue before the family court was whether the agreement to provide the health insurance was a modifiable support obligation or a non-modifiable agreement similar to a division of property. The family court found "unambiguously" that the health insurance was not support. The court denied Mr. Miles' modification. The appellate court affirmed the family court. On appeal to the Supreme Court, Mr. Miles argued that both the family court and the appellate court were wrong in holding the health insurance was a support obligation. The Supreme Court reversed both lower court decisions, holding that the agreement provided a "modifiable incident of support in the form of health and dental insurance as a matter of law." The record reflected that the change in Mr. Miles' circumstances merited a modification because his earning capacity diminished significantly since the divorce decree, while Mrs. Miles' circumstances substantially improved. The Court remanded the case to the family court for further proceedings.

After his conviction for homicide, Petitioner Lucas Bailey filed an unsuccessful application for post conviction relief. On appeal to the Supreme Court, Petitioner argued that he received ineffective assistance of counsel. Petitioner alleged his counsel failed to object to jury instructions that allowed the jury to convict him for an act that was not in the indictment. Upon careful consideration of the record below, the Supreme Court found that the trial judge may have engaged in an off-the-record discussion with the jury: "we are troubled that the decision regarding the jury instruction may have been made without the judge conferring with the attorneys." The Court vacated Petitioner's conviction and sentence, and remanded the case for a new trial. View "Bailey v. South Carolina" on Justia Law

In this divorce action, the Supreme Court was asked to review two decisions of the appellate court involving the valuation of the marital home and an award of expert witness fees. Both issues involve determinations of fact. "An appellate court should approach an equitable division award with a presumption that the family court acted within its broad discretion. The family court should be reversed only when the appellant demonstrates an abuse of discretion," not for determinations of fact. In this case, the Supreme Court reversed the appellate court's reversal of the family court because there was no clear demonstration of an abuse of that discretion. The Court reinstated the ruling of the family court. View "Lewis v. Lewis" on Justia Law

Appellant Essie Simmons and Respondent Rubin Simmons divorced in 1990. The parties entered into a settlement agreement that was approved by the family court. Central to the agreement was the requirement that Mr. Simmons give Ms. Simmons a half or third of his Social Security benefits, depending on his age when he retired. When he retired, Mr. Simmons did not pay his ex-wife. She sued, but the family court declined to hear the complaint, finding that it could not hear a case that primarily dealt with Social Security benefits. Mr. Simmons appealed the dismissal, and the appellate court reversed. The court voided the division of Mr. Simmons' benefits, holding that the Social Security Act specifically precluded parties from dividing benefits under the settlement agreement. Because the agreement was partly voided by the court, Ms. Simmons sought to reopen the matter entirely. The family court dismissed again, holding that it lacked jurisdiction to revisit the agreement. On appeal, the Supreme Court was presented with the question of whether the family court could revisit the now partially voided agreement. Upon careful review of the arguments and applicable legal authority, the Court held that "basic principles of equity suggest[ed] that all issues should be revisited by the family court." The Court recognized the practical difficulties confronting the family court, but the Court noted, "that challenge pales in comparison to [Mr. Simmons'] suggestion that we simply end this matter with the remnant of the agreement remaining valid." The Court reversed the decision of the lower court and remanded the case to the family court for further proceedings. View "Simmons v. Simmons" on Justia Law

The State appealed a circuit court order dismissing its case against Respondent Gregory Duncan. Respondent was indicted for murder after he shot and killed Christopher Spicer at his home. The court ruled that Respondent was immune from prosecution under the state Protection of Persons and Property Act. The Supreme Court found that the trial record reflected ample evidence to support the circuit court's ruling. The Court affirmed the circuit court's decision to dismiss the State's case. View "South Carolina v. Duncan" on Justia Law

Appellant Kenneth Justus was sentenced to death for the murder of Justin Bregenzer. On appeal to the Supreme Court, Appellant argued that the trial court abused its discretion when it disqualified one of his two appointed counsel. The counsel in question, Maite Murphy, had worked for the State's lead investigator as a divorce attorney. The trial court removed Ms. Murphy as Appellant's trial counsel, holding that that a former business relationship presented a conflict-of-interest issue. Upon careful consideration of the arguments and the applicable legal authority, the Supreme Court affirmed the lower court's decision to remove Appellant's counsel. View "South Carolina v. Justus" on Justia Law

This case involves the State's "working retiree program," and the propriety of its withholding retirement contributions from eligible members who returned to work with the state prior to July, 2005. Before that time, the program allowed employees to retire, then after a break, be re-hired and receive retirement benefits and a salary of up to $50,000 per year without having to pay into the pension plan. The State was ordered to refund any contributions made since July, 2005 by program members. In 2005, the State Retirement System Preservation and Investment Reform Act amended the program to require retired members pay the employee contribution as if they were active members but without accruing additional service credit. The State appealed the circuit court's order to refund the contributions. The retirees challenged the change in the program, arguing that it was unlawful for the State to change the terms of the working retiree program after the retirees "irreversibly retired" with the understanding that contributions to the pension plan would not be required. Upon careful consideration of the arguments and legal authority, the Supreme Court reversed the circuit court's holding with respect to the State's return of contributions since 2005. The Court found that the Legislature enabled the State to take the contributions when it amended the program by Act in 2005. The Court dismissed the Retirees' challenge to the State Retirement System Preservation and Investment Reform Act, finding no merit in their argument. View "Ahrens v. South Carolina" on Justia Law

Appellants South Carolina Department of Corrections (SCDC) and three of its officers appealed a circuit court order enjoining them from forwarding certain information regarding Respondent James Compton to the Department of Probation, Parole and Pardon Services (DPPPS). Respondent committed burglary, assault and battery, armed robbery and aggravated assault and battery in South Carolina. He fled to Georgia, but was apprehended there a short time later. Respondent voluntarily returned to South Carolina where he was prosecuted, found guilty, and sentenced to life plus forty-five years' imprisonment. In 1982, Respondent was "away without leave" (AWOL) for a period of time. No charges were filed against him when he returned. In 1995, Respondent went AWOL again, but he was not returned to custody until 2002. An arrest warrant and indictment were issued on escape charges, but they were "nol prossed" when the State failed to appear before the grand jury. The circuit court issued an order in 2005 for the destruction of the arrest warrant and indictment in connection with the 1995 incident. Respondent's criminal history still referenced the 1995 charges. Respondent was not granted parole because questions regarding the 1995 escape charges persisted at DPPPS hearings. Respondent petitioned the court for a declaration that SCDC failed to comply with the court order to destroy records of his 1995 escape charges. The court found that SCDC was not in willful violation of the court orde, and that the entries were in Respondent's criminal history for security and classification purposes. The court enjoined the SCDC from forwarding information regarding the 1995 escape to DPPPS. SCDC argued on appeal to the Supreme Court that the circuit court erred in granting Respondent an injunction. Upon review, the Supreme Court reasoned that "a prisoner absenting himself from a prison (commonly referred to as an escape) is a fact that exists regardless of whether charges are filed in connection with it ... Because the injunction we affirm only enjoins the dissemination of records pertaining to criminal charges and not historical facts, [SCDC] is not enjoined from forwarding information they have a duty to send to DPPPS." Accordingly, the Court affirmed the lower court's decision. View "Compton v. South Carolina Dept. of Corrections " on Justia Law

Craig Reeves was the biological father of "Baby Boy Roe." The biological mother of the child was sixteen when she found out she was pregnant. She attempted to include Mr. Reeves in the pregnancy from the onset, but he was dating another woman, and the record reflected he clearly was not interested in becoming a parent. The mother contacted an adoption agency about placing the child up for adoption and settled on Appellants "John and Jane Roe." At some point, the mother began to have reservations over her decision to give the baby up for adoption. At some point, Mr. Reeves had a change of heart over his involvement with the mother and her pregnancy. He bought some diapers and periodically bought things for the mother, but nothing to the extent that Appellants had done. the father lived with his parents, and converted some extra space in his home as a makeshift "nursery," fully expecting to take the baby home with him once it was born. Mr. Reeves went to the hospital to see "his" son when born, but the hospital informed him that the mother was a "no information" patient, and he was turned away. The next day, the mother signed an adoption consent form, and Appellants took the child home. Mr. Reeves brought suit in family court, arguing that the baby could not be adopted without his consent. The court found that his consent was needed, and ordered the child be returned to his custody. Upon review, the Supreme Court found that Mr. Reeves "did not fully grasp the opportunity to come forward and demonstrate a full commitment to the responsibilities of parenthood through prompt and good faith efforts." The Court held that Mr. Reeves' contributions were not sufficient compliance with state law to establish his right to consent to the adoption. The Court reversed the family court order pertaining to the father's consent, and awarded immediate custody of the child to Appellants. View "Roe v. Reeves" on Justia Law