Justia South Carolina Supreme Court Opinion Summaries

The disputed actions at issue here occurred during special meetings for which the Town of Mount Pleasant issued agendas listing an executive session but not indicating Town Council would take action following the executive session. Petitioner Stephen Brock, who was a member of the Town's Planning Commission and the president and general manager of a local television station, filed a complaint against the Town alleging numerous violations of the Freedom of Information Act (FOIA) and seeking declaratory and injunctive relief. The South Carolina Supreme Court granted certiorari review of the court of appeals' decision that the Town did not violate FOIA by taking unnoticed action following executive sessions at special meetings. Having carefully reviewed the record and law, the Supreme Court agreed with Petitioner that the Town technically violated FOIA and that the court of appeals erred in relying on the discussion of regular meetings in "Lambries v. Saluda County Council," (760 S.E.2d 785 (2014)), in resolving the underlying challenge concerning special meetings. The Court modified the court of appeals' decision. View "Brock v. Town of Mount Pleasant" on Justia Law

Respondent Nathaniel Teamer was convicted of first-degree burglary, felony driving under the influence (DUI) resulting in great bodily injury, and failure to stop for a blue light (FSBL) resulting in great bodily injury and sentenced to an aggregate term of thirty years in prison. Following the court of appeals' dismissal of Respondent's direct appeal, Respondent filed a post-conviction relief (PCR) application. The PCR court granted relief on four grounds. The Supreme Court granted the State's petition for a writ of certiorari to review the PCR court's decision. Finding that the PCR court erred in its interpretation of the applicable law, and in finding respondent's trial counsel was ineffective for failing to move for a directed verdict on the burglary charge. Accordingly, the PCR court's decision was reversed, and respondent's convictions and sentences were reinstated. View "Teamer v. South Carolina" on Justia Law

Petitioner Richard Burton Beekman was convicted of committing first-degree criminal sexual conduct (CSC) with a minor on his stepson (Stepson) and a lewd act upon a child on his stepdaughter (Stepdaughter). Beekman argued the court of appeals erred in affirming the trial court's denial of his motion to sever the charges because the crimes did not arise out of a single chain of circumstances and were not provable by the same evidence. Further, Beekman argued that trying the charges together unfairly prejudiced him because it allowed the jury to consider evidence the State would have been prevented from presenting in separate trials and likely created the impression in jurors' minds that Beekman had a propensity to sexually abuse children. Therefore, according to Beekman, the South Carolina Supreme Court should have reversed his convictions and remand his case for separate trials. Finding no error in the trial court's or the appellate court's decisions, the Supreme Court affirmed. View "South Carolina v. Beekman" on Justia Law

Respondent Alex Robinson was convicted of one count of trafficking in cocaine in an amount between 100 and 200 grams. He was sentenced to twenty-five years imprisonment and ordered to pay a $50,000 fine. The Court of Appeals reversed Robinson's conviction and remanded for a new trial, holding that the search-warrant affidavit did not include any information to establish the reliability of the informant. The South Carolina Supreme Court granted the State's petition for a writ of certiorari. After review, the Supreme Court held that because the search-warrant affidavit, on its face, supported a finding of probable cause, an objective law enforcement officer's belief in it could have been reasonable. Thus, the Court of Appeals erred in holding otherwise. However, because the information in the search-warrant affidavit concerning the informant/purported purchaser's reliability was intentionally false, the credibility of the entire affidavit was compromised. The Court affirmed the Court of Appeals' decision as modified. View "South Carolina v. Robinson" on Justia Law

In 2006, Alice Hancock waited in her vehicle in the parking lot of a Wal-Mart while her sister, Donna Beckham, attempted to shoplift several articles of clothing. Hope Rollings, a Wal-Mart customer service manager, noticed Beckham attempting to shoplift and alerted several other employees, including fellow manager Shawn Cox and the on-duty security guard Derrick Jones of U.S. Security Associates, Inc. (USSA), which provided security in the Wal-Mart parking lot pursuant to a contract with Wal-Mart. Ultimately, Beckham exited Wal-Mart without the clothing. However, Jones approached her in the parking lot. Beckham ran towards Hancock's vehicle, and Jones followed her in his truck and blocked Hancock's vehicle with his truck. After Beckham entered Hancock's vehicle, Hancock turned the vehicle around and drove towards the parking lot's exit, with Jones following. Hancock exited the parking lot onto a highway, and Jones followed. Approximately two miles from Wal-Mart, Hancock's vehicle left the highway and crashed. Hancock died at the scene of the accident. Petitioner Travis Roddey, the personal representative of Hancock's estate, brought an action alleging negligence on the part of Wal-Mart, USSA, and Jones. Petitioner appealed the court of appeals' decision to affirm the trial court's grant of Wal-Mart's motion for a directed verdict on Petitioner's negligence claim. Viewing the evidence in the light most favorable to the nonmoving party, the Supreme Court found that there was evidence from which a jury could determine that Wal-Mart was negligent, and that its negligence proximately caused the injuries in this case. Accordingly, the Court held that the trial court should have submitted to the jury the issues of Wal-Mart's negligence and proximate cause, and remanded for a new trial as to all of the defendants. View "Roddey v. Wal-Mart Stores" on Justia Law

Petitioner was convicted of murder, possession of a firearm during the commission of a violent crime, and pointing a firearm. He was sentenced to life imprisonment without parole. The Supreme Court affirmed petitioner's convictions and sentences on direct appeal. Petitioner then filed a post-conviction relief ("PCR") action, and sought certiorari to review the PCR judge's order denying relief. The Supreme Court granted the petition for a writ of certiorari on two issues: (1) whether the PCR judge erred in finding trial counsel was not ineffective by failing to cross-examine the State's "key" witness regarding prior inconsistent statements; and (2) whether the PCR judge erred in finding trial counsel was not ineffective by failing to preserve for appellate review the trial judge's refusal to charge the jury on the defense of others. After review, the Supreme Court found the PCR judge erred as to the first issue, and reversed on those grounds. View "Rutland v. South Carolina" on Justia Law

Five separate lawsuits were consolidated for the purposes of this opinion. County administrators and registers of deeds in Allendale, Beaufort, Colleton, Hampton, and Jasper Counties (collectively, Respondents) filed suit against MERSCORP Holdings, Inc.; Mortgage Electronic Registrations Systems, Inc. (MERS); and numerous banking institutions (collectively, Petitioners). Respondents contended Petitioners engaged in a practice of fraudulent recordings that have disrupted the integrity of the public index Respondents were statutorily required to maintain. Petitioners moved to dismiss, arguing Respondents "lack contractual standing," the lawsuit was barred by section 30-9-30 of the South Carolina Code (2007), the parties could designate MERS as mortgagee, and the complaints failed to state a cognizable claim. The motion was denied, and Petitioners appealed. The Supreme Court found that Respondents failed to state a claim and therefore reversed the trial court's denial of Petitioners' motion to dismiss. View "Kubic v. MERSCORP" on Justia Law

Michael Pearson was convicted of first-degree burglary, armed robbery, kidnapping, grand larceny, and possession of a weapon during the commission of a violent crime. The trial judge sentenced Pearson to an aggregate sentence of sixty years' imprisonment. The Court of Appeals reversed, holding the circumstantial evidence presented by the State was insufficient to submit the case to the jury. The State appealed. Viewing the evidence in the light most favorable to the State, the Supreme Court concluded the evidence could have induced a reasonable juror to find Pearson guilty. The Court found the Court of Appeals weighed the evidence and erroneously required the State, at the directed verdict stage, to present evidence sufficient to exclude every other hypothesis of Pearson's guilt. Accordingly, the Court reversed the Court of Appeals and affirmed Pearson's convictions and sentences. View "South Carolina v. Pearson" on Justia Law

Petitioner Manuel Marin was convicted of murder and possession of a firearm during the commission of a violent crime. Marin appealed, and the court of appeals affirmed, rejecting his argument that the trial court committed reversible error by refusing to instruct the jury that a person acting in self-defense has the right to continue shooting until the threat has ended. The Supreme Court, after review, disagreed but affirmed, finding that the common law rule was sufficiently encompassed in the jury charge provided by the trial court. "Because the thorough jury charge included consideration of the applicable principles of self-defense, the failure to incorporate the precise 'continuing to shoot' verbiage does not rise to the level of reversible error. We therefore affirm the court of appeals' decision as modified." View "South Carolina v. Marin" on Justia Law

From 1998 to 2000, an armed perpetrator committed six robberies of hotels in Lexington, Richland, Berkeley, and Charleston counties. During each of these robberies, the perpetrator entered the hotel, held the clerk at gunpoint, restrained the clerk with either duct tape or rope, and stole money out of the hotel safe and till. After an investigation, the police arrested Clifford Thompson for these robberies, and a grand jury indicted him on multiple counts of armed robbery and kidnapping. Thompson appealed the court of appeals' decision to affirm the circuit court's refusal to grant Thompson's request for declaratory judgments finding that: (1) his kidnapping offenses did not involve a sexual element; and (2) Thompson would not need to register as a sex offender upon his release from prison in 2020. Upon review, the Supreme Court reversed the court of appeals' decision affirming the circuit court's refusal to address whether Thompson's kidnapping offenses did not involve a sexual element, and remand for a hearing on this issue. However, because the issue of whether Thompson will be required to register as a sex offender upon his release from prison is not yet ripe, and because the SCDC's classification of Thompson as a sex offender in prison was subject to internal grievance procedures, the Court affirmed the court of appeals' decision with respect to those two issues, and allowed Thompson to file a grievance with the SCDC to become reclassified in the SCDC's system. View "Thompson v. South Carolina" on Justia Law