Justia South Carolina Supreme Court Opinion Summaries

William Crenshaw, a tenured professor of English at Erskine College, filed suit claiming he was wrongfully fired. A jury found in favor of Dr. Crenshaw and awarded him $600,000. However, after review of the College's appeal, the South Carolina Supreme Court determined the trial court properly granted Erskine's motion for judgment notwithstanding the verdict because, as a matter of law, Erskine did not breach its contract with Dr. Crenshaw. View "Crenshaw v. Erskine College" on Justia Law

Petitioner Sha'quille Washington was indicted for the murder of Herman Manigault and was convicted of the lesser included offense of voluntary manslaughter. The court of appeals affirmed Petitioner's conviction. The South Carolina Supreme Court granted petitioner's petition for certiorari review of the appellate court's judgment. After such review, the Supreme Court determined the trial court erred in giving an accomplice liability instruction, and held petitioner was prejudiced by this error. Therefore, the Court affirmed in part, vacated in part, and reversed in part, and remanded to the circuit court for a new trial on the charge of voluntary manslaughter. View "South Carolina v. Washington" on Justia Law

Appellant Don Weaver brought a declaratory judgment action to challenge the constitutionality of S.C. Code Ann. section 6-11-271 (2004), which addressed the millage levied in certain special purpose districts. Appellant owned property and was a taxpayer in the Recreation District, a special purpose district created to fund the operation and maintenance of parks and other recreational facilities in the unincorporated areas of Richland County, South Carolina. Appellant first argued section 6-11-271 was unconstitutional because it violated the South Carolina Constitution's prohibition on taxation without representation. Appellant next contended section 6-11-271 did not affect all counties equally and was, therefore, special legislation that was prohibited by the South Carolina Constitution. Appellant lastly argued section 6-11-271 was void because it violated Home Rule as set forth in the state constitution and the Home Rule Act. The circuit court found Appellant failed to meet his burden of establishing any constitutional infirmity. To this, the South Carolina Supreme Court concurred and affirmed judgment. View "Weaver v. Recreation District" on Justia Law

The South Carolina Department of Motor Vehicles (DMV) suspended Bradley Sanders' driver's license pursuant to South Carolina's implied consent statute after he refused to take a blood-alcohol test following his arrest for driving under the influence (DUI). The suspension was upheld by the Office of Motor Vehicles and Hearings (OMVH), the Administrative Law Court (ALC), and the court of appeals. Sanders argued on appeal to the South Carolina Supreme Court that the decision of the court of appeals should have been reversed due to a lack of substantial evidence in the record to support the suspension. Specifically, Sanders argued the court of appeals erred in: (1) determining there was substantial evidence that a nurse, who was working in the emergency room at the time Sanders was admitted, qualified as licensed medical personnel; and (2) holding the statements used to establish his alleged inability to submit to a breath test were not hearsay. Finding no reversible error, the Supreme Court affirmed the suspension. View "Sanders v. So. Carolina Dept. Motor Veh." on Justia Law

The South Carolina Human Affairs Commission (the Commission) brought this action against respondents Zeyi Chen and Zhirong Yang, alleging they violated the South Carolina Fair Housing Law by discriminating against a prospective tenant. The action was based on a complaint received from Stacy Woods, who reported that she responded to an ad on Craigslist for a rental residence in Mount Pleasant and was told it was not available. Woods maintained she was refused the rental property because she had a four-year-old daughter. The Commission appealed circuit court orders:(1) denying the Commission's motion pursuant to Rule 43(k), SCRCP to enforce the parties' settlement agreement; (2) finding certain information was obtained by the Commission during the conciliation process and was, therefore, subject to orders of protection and inadmissible under S.C. Code Ann. section 31-21-120(A) (2007) of the Fair Housing Law; and (3) ultimately dismissing the Commission's action based on a finding section 31-21-120(A) was unconstitutional and the entire statute was void. After review, the South Carolina Supreme Court affirmed in part, reversed in part, and remanded. The Court found the requirements of Rule 43(k) clearly were not met, for the reasons found by the circuit court. Consequently, the circuit court's order denying the Commission's motion to compel enforcement of the settlement agreement was affirmed. The Commission contended the circuit court declined to give adequate consideration to comparable federal law to aid its decision and gave no deference to the Commission's interpretation. To this, the Supreme Court agreed and reversed the circuit court as to orders of protection related to conciliation efforts. Further, the Supreme Court concurred with the Commission the circuit court erred in dismissing claims against Respondents pursuant to section 31-21-120(A) as unconstitutional. The Supreme Court held Respondents did not meet their "heavy burden" of proving the statute was unconstitutionally vague. View "So. Car. Human Affairs Commission v. Yang" on Justia Law

Petitioner Robin Herndon was convicted of voluntary manslaughter for shooting and killing her live-in boyfriend, Christopher Rowley, allegedly, in self defense. Petitioner was tried for murder; the case against Petitioner was largely circumstantial. Petitioner requested the Logan circumstantial evidence charge, but the trial court refused, opting instead for the pre-Logan circumstantial evidence charge. On appeal, there was no contention that the trial court properly refused to give a "Logan" charge. Instead, the State contended the court's failure to give the Logan charge was a harmless error, for the jury instructions as a whole were substantially correct. The court of appeals summarily accepted the State's argument and affirmed. After review, the South Carolina Supreme Court reversed and remanded, finding that while there may be cases in which a trial court's failure to five the Logan charge is indeed harmless, "this is not such a case." The State's case against Petitioner was almost exclusively circumstantial. The State relied on: (1) eyewitness testimony prior to the shooting to suggest Petitioner was angry; and (2) testimony from the pathologist explaining the pathway of the bullet could have been caused by Petitioner shooting the victim as he walked up the stairs to the house. In urging the Supreme Court to find the error was harmless, "the State entirely disregards the testimony of its own witness that it was plausible the fatal wound could have been caused by the victim charging Petitioner, exactly as Petitioner testified. The competing inferences involved in this circumstantial evidence case illustrate well the need for the Logan charge. Because the failure to provide the Logan circumstantial evidence charge was not harmless and that failure manifestly prejudiced Petitioner, we reverse and remand for a new trial." View "South Carolina v. Herndon" on Justia Law

Respondent Tommie Rae Brown sought to establish she was the survivor of the late entertainer James Brown, who died in 2006. An issue arose in the context of Respondent's claims for an elective or omitted spouse's share of Brown's estate. There was uncertainty as to Respondent's marital status because she did not obtain an annulment of her first recorded marriage until after her marriage ceremony to Brown. In January 2004, Brown filed an action to annul his marriage to Respondent, indicating the parties had recently separated. Brown alleged he was entitled to an annulment because Respondent never divorced her first husband, so their purported marriage was void ab initio. Brown asked that Respondent "be required to permanently vacate the marital residence" and noted the parties had executed a prenuptial agreement that resolved all matters regarding equitable division, alimony, and attorney's fees. Respondent's omitted spouse claims were transferred to the circuit court, which granted her motion for partial summary judgment, and denied a similar motion by the Limited Special Administrator and Trustee (LSA). The circuit court found that as a matter of law, Respondent was Brown's surviving spouse. The South Carolina Supreme Court granted certiorari review of claims made by several of Brown's children, and after such review, concluded Respondent was not Brown's surviving spouse. Consequently, the court of appeals' decision affirming the circuit court was reversed, and the matter remanded to the circuit court for further proceedings. The circuit court was directed upon remand to promptly proceed with the probate of Brown's estate in accordance with his estate plan. View "Brown v. Sojourner" on Justia Law

John Massey, Jr. was indicted for first-degree burglary, grand larceny, and criminal conspiracy. The circuit court granted a defense motion to quash the indictment for first-degree burglary on the basis the premises entered did not qualify as a dwelling. The court of appeals affirmed. The State contended on appeal to the South Carolina Supreme Court that, beyond the fact that the circuit court did not have the authority to quash a facially valid indictment on sufficiency-of-the-evidence grounds, the court of appeals erred in affirming the circuit court's ruling on the merits. To this, the Supreme Court agreed, and reversed. The matter was remanded to the circuit court for further proceedings. View "South Carolina v. Massey" on Justia Law

The South Carolina Supreme Court granted a writ of certiorari to review the court of appeals' decision in Wilson v. Gandis, Op. No. 2018-UP-078 (S.C. Ct. App. filed Feb. 7, 2018). David Wilson, John Gandis, and Andrea Comeau-Shirley (Shirley) are members of Carolina Custom Converting, LLC (CCC). Wilson filed suit against Gandis, Shirley and CCC, alleging they engaged in oppressive conduct against him. Wilson also brought a derivative action against CCC. Wilson sought a forced buyout of his membership interest by Gandis, Shirley, and CCC. CCC counterclaimed against Wilson, alleging Wilson misappropriated its trade secrets and communicated these secrets to Neologic Distribution, Inc. and to Fresh Water Systems, Inc. During a five-day bench trial, the trial court received over three hundred exhibits and heard testimony from ten witnesses. The trial court found Gandis and Shirley engaged in oppressive conduct and ordered them to individually purchase Wilson's distributional interest in CCC for $347,863.23. The trial court found in favor of Wilson on CCC's, Gandis', and Shirley's counterclaim for breach of fiduciary duty. The trial court also found in favor of Wilson, Neologic, and Fresh Water on CCC's trade secrets claim. CCC, Gandis, and Shirley appealed. In an unpublished opinion, the court of appeals affirmed the trial court and adopted the trial court's order in its entirety. After review, the Supreme Court affirmed as modified the court of appeals' decision as to Wilson's claim for oppression, affirmed the court of appeals' decision as to Gandis' and Shirley's claim for breach of fiduciary duty, and affirmed the court of appeals' decision as CCC's claim for misappropriation of trade secrets. View "Wilson v. Gandis" on Justia Law

Billy Phillips was convicted of murder and possession of a weapon during the commission of a violent crime. At trial, a DNA analyst testified Phillips could not be excluded as a contributor to a mixture of DNA recovered from two samples taken from the crime scene. The analyst conceded, however, the statistical probability that some other randomly selected and unrelated person also could not be excluded as the person who left the DNA was, for one of the samples, only one in two. Furthermore, the State failed to explain to the trial court or the jury three fundamental concepts underlying the DNA testimony the analyst gave in this particular case. Finally, in several instances, the State presented information to the trial court and the jury that was simply wrong. Taking all of this into consideration, the South Carolina Supreme Court held the trial court erred in not sustaining Phillips' objections to this testimony. The conviction was reversed and the matter remanded for a new trial. View "South Carolina v. Phillips" on Justia Law