Justia South Carolina Supreme Court Opinion Summaries

Appellant Raymondeze Rivera directly appealed his death sentence to the Supreme Court. Although Appellant raised multiple challenges, the Court was "constrained to reverse and grant a new trial based on one - the trial court's error in refusing to allow Appellant to testify during the guilt phase of his trial." View "South Carolina v. Rivera" on Justia Law

The issue before the Supreme Court in this case concerned the question of when tax liability for property is determined. Appellant Hampton Friends of the Arts challenged the Administrative Law Court's (ALC) finding that real property it acquired in March 2008 was subject to 2008 property taxes because the property was subject to taxes on December 31, 2007. Appellant contended that, as a non-profit corporation, it was entitled to a property tax exemption for the 2008 tax year. The Supreme Court disagreed and affirmed the ALC: "pursuant to settled law, the 2008 tax status of the Hampton County property was determined on December 31, 2007. Because the property was subject to property taxes as of December 31, 2007, the property is subject to 2008 property taxes." View "Hampton Friends v. So. Carolina Dept. of Revenue" on Justia Law

Petitioner John Curtis McCoy appealed the summary dismissal of his second post-conviction relief (PCR) application on the grounds it was successive, untimely, and failed to prove a newly discovered evidence claim. Further, Petitioner alleged recently discovered juror misconduct in his petition. As to the timeliness issue, the Supreme Court concluded the PCR judge misconstrued section 17-2745(A) in finding Petitioner was required to file his claim within one year after his trial, rather than one year after the remittitur was sent from his direct appeal. Furthermore, the Court found a genuine issue of fact existed as to whether Petitioner's claim was successive under section 17-27-90. The Court reversed and remanded this case for an evidentiary hearing. In addition, the Court took the opportunity in this opinion to clarify the proper legal standard for claims involving juror misconduct. View "McCoy v. South Carolina" on Justia Law

Defendant Miama Kromah was convicted of: (1) infliction of great bodily injury upon a child; and (2) unlawful neglect of a child. She appealed, arguing the trial court abused its discretion in permitting two of the State's witnesses to testify about actions they took after hearsay conversations they had with the three-year-old victim who did not testify at trial. The Court of Appeals affirmed, finding the issue was not preserved for review. The Supreme Court granted Defendant's petition for a writ of certiorari. Upon review, the Court concluded that Defendant's issue on appeal was preserved. The Court addressed it in this opinion "in the interest of judicial economy." On the merits, Defendant did not show an abuse of discretion in the trial court's admission of certain testimony or forensic evidence. Consequently, the Court upheld the Court of Appeals' decision in result. View "South Carolina v. Kromah" on Justia Law

Shenandoah Life Insurance Company brought an action to void an insurance policy it issued on the life of Lorenzo Smallwood. The circuit court granted partial summary judgment to Shenandoah, and narrowed the issue for trial to whether Lorenzo intended to defraud the insurance company when he did not disclose information related to his medical history on the insurance application. At trial, the court granted Shenandoah's motion for a directed verdict. Lakeisha Smallwood appealed the directed verdict. Upon review, the Supreme Court held that a jury could reasonably conclude that Shenandoah failed to meet its burden of proving Lorenzo made the misrepresentations with the requisite fraudulent intent. The Court reversed and remanded the case for trial. View "Shenandoah Life v. Smallwood" on Justia Law

A group of retired firefighters and police officers who worked for the City of Columbia all elected to have group health insurance provided to them by the city. Prior to July 2009, the City paid all costs to fund the group health insurance for employees and retirees. The retirees received newsletters stating that their health insurance was free and were told by the City's human resources department that retiree health insurance would be at no cost to the retiree. In planning the 2009-2010 budget, the City considered a number of cost-saving measures including shifting part of rising health care costs to participants in the group health plan. The retirees sued under claims of breach of contract, promissory estoppel, and equitable estoppel. The circuit court granted summary judgment in favor of the City on the retirees' causes of action. Seven of the thirteen retirees appealed that decision. Upon review, the Supreme Court found that the trial court properly granted summary judgment against the retirees on their contract and estoppels claims to the extent that those claims were based on an employee handbook and benefits booklet each received when they were hired. However, the Court found that the trial court erred in granting summary judgment against the retirees on their estoppel claims based upon representations made by their supervisors and the City's human resources personnel. View "Bishop v. City of Columbia" on Justia Law

Appellant Jarmel Rice was charged as a juvenile when he was fifteen years old for a series of violent crimes. Following a contested waiver from family court to general sessions court, Appellant pled guilty to three counts of armed robbery and one count of assault with intent to kill and received a sentence of eleven years in prison, with many other charges dismissed. In pleading guilty, Appellant raised no objection to the family court waiver. On appeal to the Supreme Court, Appellant sought to resurrect his family court constitutional challenge to the waiver as violative of "Apprendi v. New Jersey," (530 U.S. 466 (2000)). Because South Carolina permits only unconditional guilty pleas and no jurisdictional claim was presented, the Supreme Court concluded Appellant waived his right to assert a claim based on "Apprendi.": "[b]eyond Appellant's failure to assert a jurisdictional argument on appeal . . . Appellant's Apprendi challenge fails on the merits." The Court held that Apprendi is not applicable to a family court juvenile waiver hearing, for a decision whether to waive a juvenile to general sessions court in no manner determines the juvenile's guilt, innocence, or punishment - it merely determines the forum in which the case is to be tried. View "South Carolina v. Rice" on Justia Law

Appellant Derrick Cheeks was convicted of trafficking in crack cocaine in excess of 400 grams and possession of crack with intent to distribute within proximity to a school and received concurrent sentences of twenty-five years (trafficking) and ten years (proximity). On appeal, he contended the trial court erred in failing to find a search warrant fatally defective, and in giving an improper jury instruction. Upon review, the Supreme Court found no merit in the warrant issue, but agreed the instruction was improper. Because the Court found appellant was not prejudiced by the erroneous charge, the Court affirmed his convictions and sentences. View "South Carolina v. Cheeks" on Justia Law

The State appealed the court of appeals' decision which held that the police search and seizure of Respondent Sylvester Taylor was improper under the Fourth Amendment to the United States Constitution. Respondent was indicted for possession with intent to distribute crack cocaine. The case proceeded to trial, and the sheriff's deputy that conducted the search testified in camera regarding the discovery of the crack cocaine. Respondent was found guilty and sentenced, as a third-time drug offender, to thirty years' imprisonment. The court of appeals overturned the conviction, finding that police did not have reasonable suspicion to stop Respondent. Upon review of the trial court record, the Supreme Court held that the court of appeals erred in finding that police did not have reasonable suspicion to justify an investigatory stop of Respondent. View "South Carolina v. Taylor" on Justia Law

In a direct appeal to the Supreme Court, Appellant Dunes West Golf Club, LLC, challenged the trial court's grant of summary judgment in favor of Respondent Town of Mount Pleasant. In 2006, the Town of Mount Pleasant amended its zoning ordinance to create the Conservation Recreation Open Space zoning district, which imposed land-use restrictions on all golf course properties in Mount Pleasant, permitting only recreation and conservation uses. Appellant desired to carve out residential lots on its golf course property by designating several noncontiguous parcels as potential home sites. Because the new zoning designation did not permit construction of new homes, Appellant sought to have the golf course property rezoned to allow residential development. The Town denied the rezoning request, and Appellant filed suit, claiming the Town's actions violated its equal protection and due process rights, and amounted to an unconstitutional taking of its property. Following discovery, the Town of Mount Pleasant successfully moved for summary judgment. The Court carefully reviewed each assignment of error and found summary judgment was properly granted. View "Dunes West v. Town of Mount Pleasant" on Justia Law