Justia South Carolina Supreme Court Opinion Summaries

Appellant Jaquwn Brewer was convicted of multiple charges in connection with the shooting of two individuals at a nightclub. The issue on appeal to the Supreme Court concerned the admission of Brewer's unredacted audiotaped interrogation by the police. The Court found the admission of Brewer's interrogation was error. Nevertheless, the Court affirmed Brewer's convictions for assault and battery with intent to kill and possession of a weapon during the commission of a violent crime, finding the admission error was harmless with respect to these charges. The murder conviction was reversed and the matter remanded for a new trial. View "South Carolina v. Brewer" on Justia Law

Appellant Kenneth Morris, II appealed the trial court's denial of his motion to suppress ecstasy and marijuana discovered during a traffic stop, arguing they were obtained as the fruits of an illegal search and seizure in violation of the Fourth Amendment. The Supreme Court disagreed, finding the officers had both reasonable suspicion of criminal activity and probable cause to conduct a warrantless search of the entire vehicle. View "South Carolina v. Morris" on Justia Law

In late 2008, Cynthia McNaughton, who was in her early to mid 50's at the time, was accepted into the South Carolina Department of Education's Program of Alternative Certification for Educators (PACE program), which enabled individuals who earned a college degree but did not complete a traditional teacher preparation program, to become certified South Carolina public school teachers. When she was hired, Appellant Charleston Charter School of Math & Science, Inc. knew that McNaughton was participating in the PACE program, and that her completion of the program was contingent upon her fulfillment of further requirements, including the completion of an induction teaching year. McNaughton signed an employment agreement, which stated that McNaughton "agree[d] to be a full-time teacher at Charleston Charter School for Math and Science for the school year 2010–2011." The employment agreement further stated that it was "contingent on funding and enrollment." McNaughton received positive feedback from her students and their parents. Neither the principal nor any other faculty member experienced any problems with McNaughton's performance as a teacher, and McNaughton was never disciplined for any matter. However, on December 1, 2010 (in the middle of the school year) the principal informed McNaughton that the school was terminating her employment. The principal told McNaughton that Appellant needed to use the funds designated for McNaughton's salary to hire and pay a new math teacher because some of the students had performed poorly on a recent math achievement test. McNaughton sued and won on her wrongful termination/breach of contract complaint. The School appealed the trial court's decisions denying its motions for a directed verdict and judgment notwithstanding the verdict (JNOV); permitting the jury to award special damages; and granting attorney's fees to McNaughton. Finding no reversible error, the Supreme Court affirmed. View "McNaughton v. Charleston Charter School" on Justia Law

In 1997, Dr. Michael Hayes and Dr. Michael Taillon were working as emergency room physicians at Providence Hospital, presumably as independent contractors. Arthur Sharpe came to the Providence Hospital emergency room complaining of chest pain. Dr. Hayes and Dr. Taillon evaluated Sharpe and diagnosed him as suffering from reflux. Sharpe was discharged. Sharpe had actually suffered a heart attack, which was determined a few days later when he sought further medical care elsewhere. Because of the misdiagnosis, in 1999, Sharpe and his wife filed a medical malpractice and loss of consortium action against Providence Hospital and Dr. Hayes. The Sharpes did not name Dr. Taillon as a defendant. Providence Hospital settled with the Sharpes in 2004. In 2007, Providence Hospital filed this equitable indemnification action against Dr. Taillon and his medical malpractice insurer, The South Carolina Medical Malpractice Liability Joint Underwriting Association (collectively Respondents). Respondents moved for summary judgment on the ground that the medical malpractice statute of repose barred Providence Hospital's claim and the circuit court granted the motion on that basis. Providence Hospital appealed, and the court of appeals affirmed. The issue this case presented for the Supreme Court's review was whether the medical malpractice statute of repose applied to Providence Hospital's indemnity claim. The Court concluded that Providence Hospital's indemnity action was indeed barred by the statute of repose, and as such affirmed the trial court. View "Columbia/CSA-HS Greater Columbia Healthcare System v. So. Carolina Medical Malpractice Liability Joint Underwriting Association" on Justia Law

Employee-petitioner Judy Barnes was employed as an administrative assistant at Charter 1 Realty. On the day of her injury, Barnes was asked to check the e-mail of one of the realtors before noon. Around 11:30 a.m., Barnes left her desk and walked toward the realtor's office. However, she stumbled, fell, and sustained serious injuries: a broken left femur, broken left humerus and a torn rotator cuff.Barnes subsequently filed a claim for workers' compensation. At the hearing, Barnes testified she was hurrying to the realtor's office to check her e-mail and that caused her to fall. Evidence was also introduced that her husband did not like the shoes she wore, and he had told her she needed to pick up her feet when she walked. The single commissioner and appellate panel found that her fall was idiopathic and therefore noncompensable. The court of appeals affirmed. The Supreme Court disagreed with the commissioner and appellate panel's findings, reversed, and remanded the case for further proceedings. View "Barnes v. Charter 1 Realty" on Justia Law

Claimant-petitioner Carolyn Nicholson, a supervisor in the investigations area of child protective services for the South Carolina Department of Social Services (DSS), was on her way to a meeting when her foot caught on the hall carpet and she fell. She received treatment for pain to her neck, left shoulder, and left side connected with her fall. Nicholson's claim for workers' compensation was denied by the single commissioner because she failed to prove a causal connection between her fall and employment. The commissioner held there was nothing specific to the floor at DSS which contributed to Nicholson's fall and that she could have fallen anywhere. The question this case presented for the Supreme Court's review was whether petitioner was entitled to workers' compensation. "Despite how straightforward this issue appears to be," both the commissioner and the court of appeals found petitioner was not entitled to recover. The Supreme Court disagreed with both, reversed, and remanded the case for further proceedings. View "Nicholson v. SC Dept. of Social Services" on Justia Law

Appellant Charvus Nesbitt appealed a circuit court judgment finding that he entered a knowing and voluntary "Alford" plea to three of four charges listed in a negotiated plea agreement. On appeal, he argued that his plea agreement was a "package deal," and because his plea for one of the charges was invalid, please for the remaining charges were also invalid. The State conceded that the circuit court erred in failing to properly question and advise appellant of his rights with respect to the the charge appellant alleged was invalid. When the terms and obligations set forth in a plea agreement are not fulfilled, appellate courts may consider whether that failure constitutes harmless error. Here, Appellant received the forty-year sentence which he negotiated, and further received the benefit of having one of the charges against him essentially dropped, as his criminal record will only reflect three convictions and not four. Therefore, to the extent there was error, Appellant has suffered no prejudice. As such, the Supreme Court affirmed the circuit court. View "South Carolina v. Nesbitt" on Justia Law

In 2007, respondent Alonzo Hawes shot and killed his estranged wife in the presence of their children. Following a guilty plea to voluntary manslaughter, the trial court granted Hawes's section 16-25-90 motion for eligibility for early parole, which the court of appeals affirmed. The South Carolina Supreme Court issued a writ of certiorari to review the court of appeals' decision. Because the trial court failed to exercise discretion, which the Supreme Court concluded was likely the result of its reliance on a prior version of section 16-25-90, it vacated the court of appeals' opinion and remanded the case for reconsideration in light of the correct version of the statute. View "South Carolina v. Hawes" on Justia Law

North American Rescue Products, Inc. (NARP) brought a declaratory judgment action to determine whether P. J. Richardson had the right to purchase 7.5% of NARP's stock at a discount despite the fact that he had been terminated, the agreement to which purported to end the parties' relationship. A jury's verdict allowed Richardson to purchase the stock, but both parties appealed. The Supreme Court granted review of the appellate court's decision affirming the jury's verdict. After that review, the Supreme Court concluded the termination agreement unambiguously ended any right Richardson had to purchase the stock. The appellate court was reversed and the case remanded for entry of judgment in favor of NARP. View "North American Rescue Products v. Richardson" on Justia Law

Both CarMax Auto Superstores West Coast, Inc., and the South Carolina Department of Revenue (appealed the court of appeals' decision, reversing and remanding a decision of the Administrative Law Court (ALC) upholding the Department's use of an alternative apportionment formula to calculate CarMax West's income tax for tax years 2002-2007. When a party seeks to deviate from a statutory formula, the proponent of the alternate formula bears the burden of proving by a preponderance of the evidence that: (1) the statutory formula does not fairly represent the taxpayer's business activity in South Carolina and (2) its alternative accounting method is reasonable. The Supreme Court affirmed (as modified), and declined to remand at both parties' request. The Supreme Court affirmed the court of appeals' finding that the ALC erred in placing the burden of proof on CarMax West. Furthermore, while there was substantial evidence in the record to support the ALC's finding that the Department's alternative accounting method was reasonable, the Department failed to prove the threshold issue that the statutory formula did not fairly represent CarMax West's business activity within South Carolina. View "Carmax Auto v. South Carolina Dept. of Rev." on Justia Law