Justia South Carolina Supreme Court Opinion Summaries

In 2008, Petitioner Yancey Thompson was convicted of first degree criminal sexual conduct (CSC) with a minor, second degree CSC with a minor, and disseminating obscene material to a minor. He was sentenced to concurrent prison terms of twenty-five years, twenty years, and ten years, respectively. Petitioner appealed and the South Carolina Supreme Court affirmed his convictions. Petitioner then sought post-conviction relief (PCR). The PCR court concluded Petitioner had established his trial counsel was deficient in certain respects but denied relief on the basis that Petitioner had not proven he was prejudiced by these deficiencies. The Supreme Court concluded Petitioner's jury trial was infected by “improper corroborating evidence,” and that there was no probative evidence in the record to support the PCR court's findings that Petitioner was not prejudiced by these deficiencies. Therefore, the Court reversed the PCR court's denial of post-conviction relief and remanded to the court of general sessions for a new trial. View "Thompson v. South Carolina" on Justia Law

Respondent Michael Milledge was arrested and convicted of multiple drug-related offenses in Greenville County following a traffic stop. Milledge applied for post-conviction relief (PCR), arguing his defense counsel was deficient for failing to object at trial to the introduction of contraband found pursuant to an illegal search. The PCR court agreed and granted Milledge a new trial. After review, the South Carolina Supreme Court held the PCR court erred in finding Milledge met his burden of proof to establish prejudice. “The motivation of the deputies in this case is highly probative. While the protections of the Fourth Amendment may have been triggered had the deputies prolonged the detention and engaged in a search of Milledge and his vehicle for the purpose of finding evidence, the limited pat down performed by Deputy Lanning was solely for officer safety. To reach a different conclusion would prevent officers operating in similar high-crime areas from conducting a protective frisk when their specialized training indicates the person may be armed and would subject officers to the ‘unnecessary risks’ in performing their duties the Terry court warned against.” View "Milledge v. South Carolina" on Justia Law

Respondent Michael Milledge was arrested and convicted of multiple drug-related offenses in Greenville County following a traffic stop. Milledge applied for post-conviction relief (PCR), arguing his defense counsel was deficient for failing to object at trial to the introduction of contraband found pursuant to an illegal search. The PCR court agreed and granted Milledge a new trial. After review, the South Carolina Supreme Court held the PCR court erred in finding Milledge met his burden of proof to establish prejudice. “The motivation of the deputies in this case is highly probative. While the protections of the Fourth Amendment may have been triggered had the deputies prolonged the detention and engaged in a search of Milledge and his vehicle for the purpose of finding evidence, the limited pat down performed by Deputy Lanning was solely for officer safety. To reach a different conclusion would prevent officers operating in similar high-crime areas from conducting a protective frisk when their specialized training indicates the person may be armed and would subject officers to the ‘unnecessary risks’ in performing their duties the Terry court warned against.” View "Milledge v. South Carolina" on Justia Law

This appeal presents the South Carolina Supreme Court with the opportunity to revisit Roddey v. Wal-Mart Stores E., LP, 784 S.E.2d 670 (2016), wherein the Court reversed and remanded for a new trial after determining the Court of Appeals erred in affirming the circuit court's decision granting Wal-Mart's motion for a directed verdict on the appellant's negligence action. On remand, the circuit court, believing the new trial to be limited to the negligence action, issued an order striking the negligent hiring, training, supervision, and entrustment action and barring any evidence in support of the action on the basis of res judicata. Travis Roddey, individually and as the personal representative of Alice Hancock's estate, ("Appellant") appealed the order and the Supreme Court certified the appeal pursuant to Rule 204(b), SCACR. Wal-Mart suspected Alice Hancock's sister, Donna Beckham, of shoplifting. As Beckham was exiting the store and heading for Hancock's car, Wal-Mart's employees told Derrick Jones, an on-duty Wal-Mart security guard employed with U.S. Security Associates, Inc. ("USSA"), to delay Beckham from leaving its premises. Beckham, however, got into Hancock's car and Hancock exited the parking lot and entered the highway. Jones pursued Hancock onto the highway in contravention of Wal-Mart's policies after Wal-Mart's employees repeatedly asked him to obtain Hancock's license tag. Hancock died in a single-car accident shortly thereafter. Appellant filed suit against Wal-Mart Stores East, LP, USSA, and Jones (collectively "Respondents"), alleging negligence and negligent hiring, training, supervision, and entrustment. At the conclusion of Appellant's case, Wal-Mart moved for a directed verdict on both causes of action. The circuit court granted Wal-Mart's motion and dismissed it from the case, concluding "there is insufficient evidence that Wal-Mart was negligent, or even if they were there is [a] lack of proximate cause that the events were not foreseeable." USSA subsequently moved for a directed verdict on the negligent hiring cause of action, arguing Jones had a suspended driver's license and a criminal record did not make it foreseeable that "Jones would engage in a high speed pursuit down the highway off [Wal-Mart's] premises." The court denied the motion and both the negligence action and the negligent hiring action were sent to the jury. The Supreme Court found no reversible error in the circuit court’s judgment, and affirmed it. View "Roddey v. Wal-Mart" on Justia Law

This appeal presents the South Carolina Supreme Court with the opportunity to revisit Roddey v. Wal-Mart Stores E., LP, 784 S.E.2d 670 (2016), wherein the Court reversed and remanded for a new trial after determining the Court of Appeals erred in affirming the circuit court's decision granting Wal-Mart's motion for a directed verdict on the appellant's negligence action. On remand, the circuit court, believing the new trial to be limited to the negligence action, issued an order striking the negligent hiring, training, supervision, and entrustment action and barring any evidence in support of the action on the basis of res judicata. Travis Roddey, individually and as the personal representative of Alice Hancock's estate, ("Appellant") appealed the order and the Supreme Court certified the appeal pursuant to Rule 204(b), SCACR. Wal-Mart suspected Alice Hancock's sister, Donna Beckham, of shoplifting. As Beckham was exiting the store and heading for Hancock's car, Wal-Mart's employees told Derrick Jones, an on-duty Wal-Mart security guard employed with U.S. Security Associates, Inc. ("USSA"), to delay Beckham from leaving its premises. Beckham, however, got into Hancock's car and Hancock exited the parking lot and entered the highway. Jones pursued Hancock onto the highway in contravention of Wal-Mart's policies after Wal-Mart's employees repeatedly asked him to obtain Hancock's license tag. Hancock died in a single-car accident shortly thereafter. Appellant filed suit against Wal-Mart Stores East, LP, USSA, and Jones (collectively "Respondents"), alleging negligence and negligent hiring, training, supervision, and entrustment. At the conclusion of Appellant's case, Wal-Mart moved for a directed verdict on both causes of action. The circuit court granted Wal-Mart's motion and dismissed it from the case, concluding "there is insufficient evidence that Wal-Mart was negligent, or even if they were there is [a] lack of proximate cause that the events were not foreseeable." USSA subsequently moved for a directed verdict on the negligent hiring cause of action, arguing Jones had a suspended driver's license and a criminal record did not make it foreseeable that "Jones would engage in a high speed pursuit down the highway off [Wal-Mart's] premises." The court denied the motion and both the negligence action and the negligent hiring action were sent to the jury. The Supreme Court found no reversible error in the circuit court’s judgment, and affirmed it. View "Roddey v. Wal-Mart" on Justia Law

The issue this case presented for the South Carolina Supreme Court’s review centered on whether Petitioner David Gooldy was entitled to an implied easement where his deed incorporated by reference a plat that indicated a road, marked "50' Road," bordered the adjoining property owned by Respondent Storage Center-Platt Springs, LLC (Storage Center). The master-inequity held Gooldy was entitled to the presumption of an implied easement, which the Storage Center failed to rebut, but the court of appeals reversed, holding the presumption did not apply and that no evidence supported the master's order. The Supreme Court concluded the appellate court erred in its conclusion that the master’s decision was not supported by evidence in the record. The Court determined parties to the 1986 conveyance intended to create an easement. The implied easement encumbered the Storage Center's property as the Loflin Plat was duly recorded in its chain of title. The master’s order was reinstated. View "Gooldy v. The Storage Center" on Justia Law

The issue this case presented for the South Carolina Supreme Court’s review centered on whether Petitioner David Gooldy was entitled to an implied easement where his deed incorporated by reference a plat that indicated a road, marked "50' Road," bordered the adjoining property owned by Respondent Storage Center-Platt Springs, LLC (Storage Center). The master-inequity held Gooldy was entitled to the presumption of an implied easement, which the Storage Center failed to rebut, but the court of appeals reversed, holding the presumption did not apply and that no evidence supported the master's order. The Supreme Court concluded the appellate court erred in its conclusion that the master’s decision was not supported by evidence in the record. The Court determined parties to the 1986 conveyance intended to create an easement. The implied easement encumbered the Storage Center's property as the Loflin Plat was duly recorded in its chain of title. The master’s order was reinstated. View "Gooldy v. The Storage Center" on Justia Law

Florence County challenged the validity of the West Florence Fire District, arguing that it violated the South Carolina Supreme Court's decision in Wagener v. Smith, 71 S.E.2d 1 (1952) and conflicted with the state's constitutional provisions concerning special legislation and home rule. The circuit court held in favor of Florence County on all three grounds, and the West Florence Fire District appealed. The South Carolina Supreme Court affirmed on constitutional grounds. View "County of Florence v. West Florence Fire District" on Justia Law

This direct cross-appeal to the South Carolina Supreme Court involved the scope of the authority the Department of Revenue (DOR) to enforce various provisions of state law relating to the imposition of a transportation penny tax by Richland County (County) and the County's expenditure of the funds generated by the tax. After DOR conducted an audit and informed the County that DOR intended to cease future remittances to the County based on purported misuse of funds, the County filed a declaratory judgment action in circuit court, arguing DOR lacked the authority to stop payments and seeking a writ of mandamus compelling DOR to continue remitting revenues. DOR counterclaimed seeking a declaration that the County's expenditures were unlawful, an injunction to prohibit future unlawful expenditures, and alternatively, the appointment of a receiver to administer the County's tax revenues. Following a hearing, the circuit court issued a writ of mandamus compelling DOR to remit the tax revenues, denied injunctive relief, and refused to appoint a receiver. Both the County and DOR appealed. After review, the Supreme Court affirmed in all respects except it reversed the circuit court's denial of DOR's request for injunctive relief. DOR was entitled to an injunction requiring the County to expend the funds generated by the tax solely on transportation-related projects in accordance with the law. View "Richland County v. So. Carolina Dept. of Revenue" on Justia Law

Stepheno Alston was tried in absentia and convicted by a jury of trafficking in cocaine. The trial judge sentenced Alston to twenty-five years' imprisonment. On appeal, the Court of Appeals affirmed Alston's conviction and sentence, upholding the trial judge's denial of Alston's motion to suppress evidence found in his vehicle following a traffic stop. Specifically, the Court of Appeals agreed with the trial judge that: (1) the arresting officer had (a) probable cause to stop Alston's vehicle for a violation of South Carolina's failure to maintain a lane statute and (b) reasonable suspicion to support a brief investigatory detention; (2) the officer had reasonable suspicion that illegal activity was occurring to justify extending the duration of the traffic stop; and (3) Alston voluntarily gave his consent to the officer to search his vehicle. The South Carolina Supreme Court granted Alston's petition for a writ of certiorari to review the decision of the Court of Appeals. Based on South Carolina rules of statutory construction, the Supreme Court held the offense of failure to maintain a lane was not a strict liability offense. As a result, an officer must consider all relevant circumstances in deciding whether to stop a vehicle for a violation of this statute. Applying this interpretation to the facts of the instant case, we conclude there is evidence to support the trial judge's finding that the initial traffic stop was valid. Further, the Court found evidence to support the trial judge's determination that the arresting officer had reasonable suspicion of criminal activity to extend the scope of the stop beyond its initial purpose and that Alston voluntarily consented to the warrantless search. Therefore, while the Supreme Court agreed with the result reached by the Court of Appeals, it modified its analysis regarding the interpretation of section 56-5-1900 and the basis for which the officer had reasonable suspicion to extend the duration of the traffic stop. Accordingly, the decision of the Court of Appeals was affirmed as modified. View "South Carolina v. Alston" on Justia Law