Justia South Carolina Supreme Court Opinion Summaries

Robert Prather was convicted of murder and strong arm robbery. The trial court sentenced Prather to concurrent prison terms of thirty years for murder and ten years for strong arm robbery. Prather appealed, and a divided court of appeals reversed and remanded the case for a new trial. The South Carolina Supreme Court granted the State's petition for a writ of certiorari, and after review, held that the trial court did not err in admitting the State's reply testimony. Prather's additional sustaining grounds were without merit. The Court therefore reversed the court of appeals and reinstated Prather's convictions. View "South Carolina v. Prather" on Justia Law

Petitioners Phillip and Jeanne Ethier appealed a verdict in favor of Respondent Dr. Guy Bibeau, who misdiagnosed a popliteal aneurysm as a probable spider bite. During voir dire, the court asked prospective jurors whether they ever had a "close social or a personal relationship" with either the Ethiers or Dr. Bibeau. After no one indicated they did, the court asked the same question about the list of potential witnesses, which included Jerilyn Wadford and Rhonda Gwynn, two nurses who examined Ethier, and the CEO of Fairfield Memorial, Mike Williams. To this question, juror Teresa Killian informed the court, "I used to work at Fairfield Memorial Hospital with Mike Williams." Killian never disclosed that she also worked with Bibeau or the two nurses. After trial, the Ethiers' counsel learned Killian previously worked with Bibeau and the nurses, and that Killian had discussed her knowledge of them with other jurors. One of the jurors, Sandra Carmichael, attested Killian stated she knew the nurses as well as Bibeau. Carmichael also noted that during jury breaks, Killian repeatedly discussed Bibeau's skills as a doctor. Four jurors said Killian vouched for the skill, proficiency, and truthfulness of all three during jury breaks. Carmichael testified that Killian's statements affected her vote, as she initially believed Bibeau was more negligent. Nevertheless, while the trial court found Killian had engaged in premature deliberations, it found no prejudice. The court also believed Killian did not intentionally conceal that she knew Bibeau and the three nurses through her previous employment, contending the question was ambiguous because it only addressed "close personal or social relationships." Accordingly, the trial court denied the Ethiers' motion for a new trial. Petitioners contended the court of appeals erred in affirming the trial court's decision to deny granting a new trial based on intentional juror concealment and premature deliberations. The South Carolina Supreme Court concluded Killian's intentional disregard of the trial court's repeated instructions not to engage in premature deliberations directly affected the verdict. "Killian discussed matters that were not introduced as evidence, and bolstered other evidence that had been admitted. Further, Killian's conduct is egregious, as she repeatedly discussed the case after being instructed not to do so." Judgment was reversed and the matter remanded for a new trial. View "Ethier v. Fairfield Memorial" on Justia Law

Danny Crane sought workers' compensation benefits for hearing loss and brain injuries he alleged he suffered in a work-related accident. The workers' compensation commission denied most of Crane's claims, finding he was not entitled to benefits for temporary total disability, permanent impairment, or future medical care. The primary basis for denying these three claims was the commissioner who initially heard the case found Crane was not credible. The court of appeals reversed the commission's denial of temporary total disability benefits, but otherwise affirmed. The South Carolina Supreme Court reversed the commission's denial of permanent impairment and future medical care benefits, finding the commission erred in denying Crane's claims based on credibility without explaining any basis on which credibility could justify ignoring objective medical evidence. The matter was remanded to the commission for a new hearing on all three claims, and before a different commissioner. View "Crane v. Raber's Discount Tire Rack" on Justia Law

In August 2013, Timothy York drowned when his boat capsized on a pond at Longlands Plantation in Greeleyville, South Carolina. The deceased's brother and personal representative of the estate filed a claim for death benefits under the Workers’ Compensation Act. Although there were initially several individuals who were potential dependents, only York's mother and his girlfriend, Yvonne Burns, claimed death benefits. Burns noted she began seeing the deceased in the late 1990s, but the parties separated before reuniting sometime in 2004-2005. She worked approximately fifty hours per week as a nurse's aide, and filed as head of the household on her tax returns, indicating no one else could claim her as a dependent. Her house was in her name, and she only used "York" on a furniture contract, purportedly because she planned to marry him. Although several witnesses testified she planned to marry while others were unaware of this fact, no one testified that they were in fact married. Burns claimed she was the deceased's common-law wife or alternatively, that she was a dependent under the Act. Whether Burns could qualify as a dependent was the issue this case presented for the South Carolina Supreme Court’s review. The commission found that because Burns was engaged in an illicit relationship in violation of South Carolina’s fornication statute, she could not recover the death benefits as a matter of public policy. The court of appeals reversed, finding, notwithstanding the fact the girlfriend’s initial claim was based on being the deceased's common-law wife, there was no evidence of fornication in the record. Because the relevant facts were not in dispute, the Supreme Court reversed and awarded benefits to the deceased’s mother. View "York v. Longlands Plantation" on Justia Law

Petitioner Robert Moore was convicted by jury and sentenced to thirty years’ imprisonment for the attempted murder of Travis Hall. Hall was shot in the head and left for dead in a vehicle in a Taco Bell parking lot following a drug deal gone wrong. In the immediate aftermath of the shooting, law enforcement officers found three cell phones, including one later identified as Petitioner's in the area of the driver's floorboard after emergency medical personnel removed Hall from the vehicle. Without obtaining a warrant, the officers removed the cell phones' subscriber identity module (SIM) cards to determine ownership. The officers then obtained a warrant to search the contents of Petitioner's phone. Petitioner's subsequent motion to suppress all evidence acquired from the phone was denied, as the trial court found Petitioner had abandoned his phone. A divided court of appeals' panel affirmed Petitioner's conviction on the basis of inevitable discovery. After review, the South Carolina Supreme Court affirmed. View "South Carolina v. Moore" on Justia Law

Petitioners, consisting of several citizens groups and neighborhood associations, sought a contested case hearing in the administrative law court (ALC) to challenge the propriety of state environmental authorizations issued by the South Carolina Department of Health and Environmental Control (DHEC) for a project relocating and expanding the passenger cruise facility at the Union Pier Terminal (the Terminal) in downtown Charleston. Petitioners contended they had standing to seek this hearing as "affected persons" under section 44-1- 60(G) of the South Carolina Code (2018). The ALC concluded Petitioners did not have standing and granted summary judgment to Respondents. The ALC terminated discovery and also sanctioned Petitioners for requesting a remand to the DHEC Board. The court of appeals affirmed. The South Carolina Supreme Court, however, concluded Petitioners did have standing, and thus reversed the grant of summary judgment and remanded the matter to the ALC for a contested case hearing. View "Preservation Society v. SCDHEC" on Justia Law

This case concerned accreting land along the South Carolina coast that owned by the Town of Sullivan. Petitioners Nathan and Ettaleah Bluestein and Theodore and Karen Albenesius (collectively, Petitioners) bought property in the Town that abutted the accreting land. Petitioners' properties were once considered oceanfront lots only a short distance from the beach, but due to accretion, the properties were now a substantial distance away. The accreting land was subject to a 1991 deed, which set forth certain rights and responsibilities respecting the condition of the property and the Town's duties concerning upkeep of the land. Petitioners were third party beneficiaries of the 1991 deed. Petitioners argued the 1991 deed mandated the Town keep the vegetation on the land in the same condition as existed in 1991, particularly as to the height of shrubs and vegetation. Conversely, the Town contended the 1991 deed granted it unfettered discretion to allow unchecked growth of the vegetation on the accreting land. The South Carolina Supreme Court determined all parties cherrypicked language from the 1991 deed to support their respective interpretations of the deed. But contrary to the holding of the court of appeals and the trial court's findings, the Supreme Court held the deed was “far from unambiguous;” because the 1991 deed is ambiguous in terms of the Town's maintenance responsibilities, the court of appeals erred in affirming the entry of summary judgment for the Town. As a result, the matter was remanded to the trial court for further proceedings. View "Bluestein v. Town of Sullivans Island" on Justia Law

Eric Spears was indicted for trafficking crack cocaine between ten and twenty-eight grams. Spears moved to suppress the evidence of the drugs seized from his person on the ground he was seized in violation of the Fourth Amendment. The trial court denied the motion to suppress, and Spears was convicted as charged. The trial court sentenced Spears to thirty years in prison. A divided court of appeals reversed Spears' conviction. The South Carolina Supreme Court granted the State's petition for a writ of certiorari to review the court of appeals' decision, and reversed, thus upholding Spears' conviction. The Supreme Court found evidence in the record to support the trial court's finding that Spears engaged in a consensual encounter with law enforcement and that Spears' subsequent actions created a reasonable suspicion that he may have been armed and dangerous - justifying law enforcement's Terry frisk that led to the discovery of the offending crack cocaine in Spears' pants. View "South Carolina v. Spears" on Justia Law

Respondents, individually and as members of a putative class, brought a declaratory judgment action against the South Carolina Department of Revenue seeking refunds of amounts garnished from their wages by the Department to satisfy delinquent debts they allegedly owed to other governmental entities. The sole issue on appeal centered on the circuit court's grant of Respondents' motion to strike one defense from the Department's answer to Respondents' second amended complaint: that South Carolina Revenue Procedures Act (RPA) subsection 12-60-80(C) prohibited this action from proceeding as a class action against the Department. The Department appealed the circuit court's order to the court of appeals, and the Supreme Court certified the Department's appeal pursuant to Rule 204(b) of the South Carolina Appellate Court Rules. After review, the Supreme Court reversed the circuit court and held this case could not proceed as a class action against the Department. View "Aiken v. So. Carolina Dept. of Rev." on Justia Law

In the course of a gun battle between mutual combatants, a bullet fired at Petitioner Aaron Young Jr. (Young Jr.) missed its intended mark and killed an unintended victim. Young Jr. and his father Aaron Young Sr. (Young Sr.) willingly engaged a rival, Tyrone Robinson, in a residential neighborhood. The battle ended when Robinson shot and killed an unintended victim, an eight-year-old child who was playing in the area. The State charged all three combatants with the murder of the victim. Robinson's murder charge stemmed from a straightforward application of the doctrine of transferred intent. The Youngs' murder charges stemmed from an application of the doctrine of mutual combat. The South Carolina Supreme Court held mutual combat could properly serve as the basis for a murder charge for the death of a non-combatant under the "hand of one is the hand of all" theory of accomplice liability. The Court therefore found the law sanctioned holding Young Jr. responsible for the actions of Robinson in causing the victim's death, and affirmed Young Jr.'s murder conviction and sentence. View "South Carolina v. Young" on Justia Law