Justia South Carolina Supreme Court Opinion Summaries

Following the 2020 census, South Carolina was required to redraw its congressional districts to ensure population equality among the seven districts. The most significant changes involved Districts 1 and 6, with District 1 being overpopulated and District 6 underpopulated. The redistricting process, led by Senator Chip Campsen, resulted in a plan that increased the Republican advantage in District 1 by unifying certain counties and shifting precincts with high Democratic vote shares into District 6. The plan was enacted in 2022 and used in subsequent elections.Previously, the United States Supreme Court reviewed the plan in Alexander v. South Carolina State Conference of the NAACP, 602 U.S. 1 (2024), focusing on claims of racial gerrymandering. The Supreme Court found that the legislature’s primary intent was partisan advantage, not racial discrimination, and held that claims of partisan gerrymandering are nonjusticiable under the U.S. Constitution. After the plaintiffs voluntarily dismissed their remaining federal claims, the League of Women Voters of South Carolina filed a petition in the Supreme Court of South Carolina, arguing that the plan constituted an unconstitutional partisan gerrymander under several provisions of the South Carolina Constitution.The Supreme Court of South Carolina, exercising its original jurisdiction, held that claims of partisan gerrymandering present a nonjusticiable political question under the state constitution. The court found that South Carolina’s constitution and statutes do not contain provisions that prohibit or limit partisan gerrymandering, nor do they provide judicially manageable standards for adjudicating such claims. The court concluded that the authority to draw congressional districts is textually committed to the legislature and denied the League’s request for relief, dismissing the claims with prejudice. View "League of Women Voters of South Carolina v. Alexander" on Justia Law

The case concerns a defendant who was arrested and indicted for the murder of an individual named Donald Blake, with the allegation being that the murder was committed by blunt force trauma. At trial, the court instructed the jury on both murder and, over the defendant’s objection, the lesser-included offense of voluntary manslaughter. After more than five hours of deliberation, the jury returned a verdict of not guilty on murder and guilty on voluntary manslaughter. During jury polling, the eleventh juror indicated that the guilty verdict for manslaughter was not her true verdict, explaining she had been pressured by other jurors and maintained a not guilty stance. The trial judge, without instructing the jury to continue deliberations and over the objections of both parties, questioned the dissenting juror individually and then declared a mistrial.Following the mistrial, the State sought to retry the defendant for murder. The defendant moved for habeas corpus and for entry of a verdict of acquittal, arguing that jeopardy had attached to the murder charge because the jury had returned a final not guilty verdict. The Circuit Court denied relief, holding that jeopardy had not attached and that the State could retry the defendant for murder. The defendant’s appeal to the South Carolina Court of Appeals was dismissed as not immediately appealable, and his petitions for supersedeas and habeas corpus were denied. The Supreme Court of South Carolina then issued a common law writ of certiorari to review whether the State could retry the defendant for murder, and later requested briefing on the voluntary manslaughter charge as well.The Supreme Court of South Carolina held that jeopardy attached to both the murder and voluntary manslaughter charges. The Court found the not guilty verdict on murder was final and that the trial court’s sua sponte declaration of a mistrial, without manifest necessity and without instructing the jury to continue deliberations, barred retrial on both charges under double jeopardy principles. The Court reversed the lower court’s ruling, holding the State may not retry the defendant for either offense. View "The State v. Erb" on Justia Law

Law enforcement arrested the defendant after discovering large quantities of methamphetamine and fentanyl in his vehicle. He was indicted for trafficking in methamphetamine and trafficking in illegal drugs under South Carolina law. The defendant entered a deferred plea agreement, agreeing to cooperate as a confidential informant in exchange for deferred sentencing. However, after being re-arrested on new drug charges, he ultimately pled guilty to both trafficking charges. Two years later, he moved to vacate his guilty plea to trafficking in illegal drugs, arguing that the statute under which he was charged did not criminalize trafficking in fentanyl, a synthetic opioid, and thus he had pled guilty to a nonexistent offense.The Circuit Court for Greenville County denied the motion to vacate, reasoning that the defendant had received a benefit by pleading to trafficking rather than a more serious charge and that his conduct was clearly criminal. The court did not specifically address whether fentanyl fell within the statutory language but imposed concurrent sentences for both trafficking convictions. The defendant appealed, contending that the indictment failed to state an offense and that the court lacked subject matter jurisdiction to accept his plea.The Supreme Court of South Carolina affirmed the conviction and sentence. The court held that even if the statute did not encompass fentanyl, any defect in the indictment was non-jurisdictional and was waived by the defendant’s guilty plea. The court clarified that subject matter jurisdiction is not implicated by defects in an indictment charging a recognized crime, and that a guilty plea waives all non-jurisdictional challenges. Therefore, the defendant could not challenge his conviction on the grounds asserted after pleading guilty. View "The State v. Sweet" on Justia Law

Following a motor vehicle accident in which a tractor-trailer driven by Mervin Johnson rear-ended Kacey and Charinrath Green’s Tesla multiple times on I-26, the Greens filed suit against Johnson. The accident resulted in relatively minor property damage and medical expenses totaling approximately $12,826. The Greens testified to ongoing pain and suffering, some loss of income, and property depreciation. Johnson did not respond to the complaint, resulting in a default judgment. At a damages hearing, the master-in-equity awarded the Greens $1.76 million in actual and punitive damages, based largely on their testimony and a video of the accident.After the default judgment, Johnson moved to set aside the entry of default and the damages award, citing health issues and arguing the damages were grossly disproportionate to the actual harm. The master denied relief from default but later reduced the damages to $250,000 ($190,000 actual, $60,000 punitive), finding the original award excessive in light of the evidence. The master omitted a $10,000 property damage award previously included. The Greens moved for reconsideration, which was denied. On appeal, the South Carolina Court of Appeals affirmed the denial of relief from default but vacated the reduced award, reinstating the original $1.76 million.The Supreme Court of South Carolina reviewed the case and held that a party in default may satisfy the “meritorious defense” requirement by showing a defense as to the amount of damages or proximate cause, not just fault. The Court affirmed the denial of relief from default, reversed the reinstatement of the $1.76 million award, and reinstated the master’s reduced award with two modifications: the master must allocate the damages between the Greens and add $10,000 for property damage to Mr. Green’s share. The case was remanded for these adjustments. View "Green v. Johnson" on Justia Law

Two drivers, McGee and Hudgins, were involved in a road-rage incident that ended with McGee crashing into Green’s vehicle, causing her injuries. Green and her husband sued both drivers. Before filing suit, Green received $100,000 from McGee’s insurer in exchange for a covenant not to execute judgment against McGee. Green’s underinsured motorist (UIM) carrier, Progressive, defended the suit in McGee’s name. The jury found McGee 60% at fault and Hudgins 40% at fault, and determined both acted recklessly, willfully, and wantonly. The jury awarded Green $88,546.78 in actual damages and $35,000 in punitive damages against each defendant.The Circuit Court for Spartanburg County combined the actual and punitive damages for a total of $158,546.78, subtracted the $100,000 payment from McGee’s insurer, and allocated the remaining $58,546.78 between McGee and Hudgins based on their respective percentages of fault. On appeal, the South Carolina Court of Appeals altered the setoff calculation, allocating the $100,000 payment first to McGee’s share, then applying any remainder to Hudgins’ share, resulting in a net judgment of $58,546.78 against Hudgins and $0 against McGee.The Supreme Court of South Carolina reviewed the setoff calculation. It held that, because the jury found both defendants acted recklessly, willfully, and wantonly, joint and several liability applied to the actual damages, making the percentage allocation of fault irrelevant. The court further held that the $100,000 payment could only be set off against the actual damages, not the punitive damages, as punitive damages are not for the “same injury.” The court reversed the Court of Appeals, holding Green is entitled to a net judgment of $23,546.78 against McGee and $35,000 against Hudgins, and remanded for entry of judgment in those amounts. View "Green v. McGee" on Justia Law

A certified registered nurse anesthetist, who had already retired and was receiving retirement benefits, resumed work at a medical center. He and other similarly situated salaried healthcare workers received additional pay for working undesirable shifts, such as weekends, holidays, late hours, on-call, and for hours worked beyond their scheduled shifts. This extra compensation, referred to as the "Wages in Controversy," was subject to mandatory deductions for the South Carolina Retirement System (SCRS). The plaintiff challenged these deductions, arguing that the extra pay should not be considered "earnable compensation" under the SCRS Act and thus should not be subject to retirement contributions.The United States District Court for the District of South Carolina, recognizing that the resolution of the plaintiff’s claims depended on the interpretation of state law, certified a question to the Supreme Court of South Carolina. The question was whether the Wages in Controversy constituted "earnable compensation" under South Carolina law, making them subject to mandatory employer deductions for SCRS contributions.The Supreme Court of South Carolina held that the Wages in Controversy are "earnable compensation" as defined by the SCRS Act. The court reasoned that these payments, although labeled differently by the employer, were all compensation for hours actually worked and not irregular, one-time, or bonus payments excluded by statute. The court concluded that such pay is subject to mandatory employer deductions under the relevant statutory provisions. The certified question was answered accordingly. View "Luce v. Lexington County Health Services District, Inc." on Justia Law

James E. Carroll, Jr. signed a contract with Isle of Palms Pest Control, Inc. and SPM Management Company, Inc. for termite protection services for his home. The contract specified the use of the Exterra Termite Interception and Baiting System, with a liability limit of $250,000 for new termite damage. However, the respondents abandoned the bait station system without informing Carroll and began using a liquid application, which was allegedly done negligently. Carroll continued to renew the bait station contract, unaware of the change, and discovered significant termite damage to his home ten years later.Carroll sued the respondents for negligence and breach of contract. The Circuit Court granted summary judgment to the respondents on the negligence claim, citing the economic loss rule, which confined Carroll's remedy to the breach of contract action. The Court of Appeals affirmed this decision.The Supreme Court of South Carolina reviewed the case and reversed the lower courts' decisions. The court clarified that the economic loss rule applies only in the product liability context when the only injury is to the product itself. Since the contract did not involve the sale of a product, the economic loss rule did not apply. The court found that the respondents' conduct in secretly switching to a liquid termiticide application was beyond the contract's scope, creating a duty of due care. The court held that there was sufficient evidence to create a genuine issue of material fact regarding the respondents' negligence and its proximate cause of the termite damage. The case was remanded for further proceedings, with the $250,000 liability limitation applying only if the verdict is based solely on the breach of contract claim. View "Carroll v. Isle of Palms Pest Control, Inc." on Justia Law

Meredith Logan Whitehurst was cited for violating the Town of Sullivan's Island's Disorderly Conduct Ordinance after loudly berating her Uber driver with profanity and racial and xenophobic epithets at nearly 2:00 a.m. The driver, an Egyptian-born immigrant, testified that Whitehurst's loud phone conversation disturbed his driving, and when he asked her to be quiet, she began mocking and cursing him. After stopping the car and asking Whitehurst and her friend to exit, Whitehurst continued to yell offensive remarks at the driver. The police were called, and Whitehurst was cited for public disorderly conduct.Whitehurst was tried by a jury in the Town's Municipal Court, which found her guilty and fined her $1,040. She moved for a new trial, which was denied, and then appealed to the circuit court, which affirmed the conviction. Whitehurst then appealed to the South Carolina Supreme Court, arguing that the Ordinance violated her First Amendment rights, was unconstitutionally vague, and that the trial court erred in various procedural rulings, including denying her motion to suppress the Uber video.The South Carolina Supreme Court affirmed the lower court's decision. The Court held that the Ordinance was content-neutral and served the Town's significant interest in controlling noise levels, thus not infringing on Whitehurst's First Amendment rights. The Court also found that the Ordinance was not unconstitutionally vague, as it provided fair notice of the prohibited conduct and included a scienter requirement. Additionally, the Court deemed Whitehurst's arguments regarding the multiple subsections of the Ordinance and the motion to suppress the Uber video as conclusory and abandoned due to lack of supporting authority. View "Whitehurst v. Town of Sullivan's Island" on Justia Law

Charles Dent was accused of sexually abusing his granddaughter, J.M., when she was eight or nine years old. The alleged abuse occurred during periods when Dent visited his daughter’s family in South Carolina. The victim disclosed various acts of abuse, including being forced to perform fellatio, digital penetration, cunnilingus, and being shown obscene material. The State indicted Dent on two counts of disseminating obscene material to a minor and two counts of criminal sexual conduct with a minor (CSCM) in the first degree, specifically alleging fellatio as the sexual battery in both CSCM indictments.At trial in the Circuit Court for Beaufort County, the State presented evidence through forensic interviews and the victim’s testimony. The victim described only one instance of fellatio, which she located at House 1, not House 2. Dent moved for a directed verdict on the CSCM charge related to House 2, arguing there was no evidence of fellatio at that location. The trial court denied the motion and, over Dent’s objection, instructed the jury on the full statutory definition of sexual battery, including acts not charged in the indictment. The jury convicted Dent of the CSCM charge for House 2 and both dissemination charges, but acquitted him of the CSCM charge for House 1. The South Carolina Court of Appeals affirmed the convictions after remand.The Supreme Court of South Carolina held that the trial court erred by denying Dent’s motion for a directed verdict on the CSCM charge for House 2, as there was no evidence of fellatio at that location, and by instructing the jury on unindicted acts of sexual battery. The Court reversed Dent’s CSCM conviction but affirmed his convictions for dissemination of obscene material to a minor. The Court also rejected Dent’s procedural challenge regarding the composition of the appellate panel. View "State v. Dent" on Justia Law

Mitchell Rivers was convicted of Homicide by Child Abuse (HCA) following the death of his four-month-old adoptive child, who died from asphyxiation. During the trial, the State introduced evidence of the child's prior injuries, which were unrelated to the cause of death. Rivers' trial attorney objected to this evidence pretrial but failed to renew the objection during the trial, leaving the issue unpreserved for appeal. Rivers subsequently filed for post-conviction relief (PCR), claiming ineffective assistance of counsel.The PCR court denied relief, finding that Rivers was not prejudiced by his attorney's failure to renew the objection. However, the court of appeals reversed this decision, holding that Rivers was prejudiced by his attorney's errors, as there was no nexus between the collateral injury evidence and the circumstances surrounding the child's death.The Supreme Court of South Carolina reviewed the case and reversed the court of appeals' decision. The Supreme Court found that even if the collateral injury evidence had been excluded, there was no reasonable probability that the jury's verdict would have been different. The court noted that Rivers' actions, including his failure to seek medical assistance after the child resumed wheezing and his inability to perform CPR, demonstrated a conscious disregard for the risk of the child's death, thus establishing extreme indifference beyond a reasonable doubt. Consequently, Rivers failed to satisfy the prejudice prong of the Strickland test for ineffective assistance of counsel. The decision of the court of appeals was reversed. View "Rivers v. State" on Justia Law