Justia South Carolina Supreme Court Opinion Summaries

In South Carolina, a defendant, William C. Sellers, was convicted of murder in connection with the killing of Johnny Hydrick. The State presented evidence that Sellers personally murdered Hydrick during a burglary and robbery attempt to steal Oxycodone, guns, and cash from Hydrick's home. The State also presented an alternative theory that Sellers was guilty under the doctrine of "the hand of one is the hand of all" because he and another man agreed to carry out the burglary and robbery, during which one or both of them fatally beat Hydrick.The Supreme Court of South Carolina affirmed the lower court's decision. The court addressed two main issues. First, it considered whether the trial court's jury instruction defining malice partly as "the intentional doing of a wrongful act without just cause or excuse" improperly shifted the burden of proof to Sellers. The court found that the instruction did not shift the burden because the State was required to prove beyond a reasonable doubt that Sellers acted "without just cause or excuse."Second, the court examined whether the State presented sufficient evidence to support instructing the jury on Sellers' criminal liability under the doctrine of "the hand of one is the hand of all." The court found that the State had presented evidence that Sellers and another man had agreed to commit the burglary and robbery, and that both had beaten Hydrick during the course of these crimes. Thus, the instruction was supported by the evidence.Therefore, the court affirmed Sellers' conviction for murder. View "State v. William C.Sellers" on Justia Law

In South Carolina, Phillip Francis Luke Hughes, on behalf of the estate of his late mother, Jane Hughes, sued Bank of America for fraud, fraudulent concealment, and breach of contract, alleging that the bank charged insurance premiums in connection with a home equity line of credit his parents obtained in 2006, even though they declined the insurance offer. The bank argued that the claims did not survive Jane Hughes's death, were barred by res judicata and the statute of limitations, and that their motion for sanctions was not premature.The Supreme Court of South Carolina held that the claims for fraud and fraudulent concealment survived Jane Hughes's death. However, it also held that all three claims were barred by the res judicata effect of rulings in related federal court litigation. The court affirmed as modified in part and reversed in part the lower court's decision. The court also affirmed the lower court's decision that the sanctions motion was not premature. The court further held that the claim for breach of contract accompanied by a fraudulent act survived Jane Hughes's death, but was also barred by res judicata.As for the statute of limitations issue, the court held that the statute of limitations had expired before the action was commenced and that the plaintiff was precluded from relitigating the equitable tolling issue. The court remanded Bank of America's sanctions motion to the lower court for disposition. View "Hughes v. Bank of America" on Justia Law

In this case, Jeffrey L. Cruce, the former head football coach and athletic director for Berkeley High School, filed a lawsuit against the Berkeley County School District (the District) for wrongful termination and defamation. The defamation claim was based on an email circulated by an athletic trainer questioning the integrity of student athlete files maintained by Cruce. The court of appeals had ruled that Cruce was a public official for the purposes of defamation law, and thus required to prove actual malice to win his defamation claim, which the South Carolina Tort Claims Act (SCTCA) grants the District immunity from.The Supreme Court of South Carolina disagreed, stating that being a public employee and enjoying media attention does not make Cruce a public official, as he did not have any official influence or decision-making authority about serious issues of public policy or core government functions. The court also rejected the District's claim that Cruce was a public figure, stating that the controversy over Cruce's coaching tactics did not affect large segments of society and was unrelated to the defamation claim. The court ruled that Cruce was not a public official, not a public figure, and that his defamation claim was supported by evidence, reversing the decision of the court of appeals and reinstating the jury's damages award. View "Cruce v. Berkeley County School Dist" on Justia Law

The Supreme Court of South Carolina affirmed the decision by the court of appeals in the case of Tommy Lee Benton, who was convicted for the murder of Charles Bryant Smith, two counts of first-degree burglary, one count of first-degree arson, and one count of third-degree arson. Benton's first trial was declared a mistrial due to his failure to disclose his alibi, which he intended to support via his great-grandmother's testimony. Benton claimed that his second trial and ensuing convictions were barred by double jeopardy. The court, however, found that the mistrial was declared due to "manifest necessity," hence, there was no double jeopardy violation.Benton also argued against the admissibility of gruesome crime scene photographs and certain text and Facebook messages. The court upheld the trial court's decision, asserting that the photographs provided important context to the testimony and other key evidence. The court noted that while the photographs were disturbing, any error in admitting them was harmless as they did not significantly contribute to the verdict. The court also affirmed the admissibility of the text and social media messages. View "State v. Benton" on Justia Law

In this case, the South Carolina Supreme Court upheld the constitutionality of a state statute that limits reimbursement of reestablishment expenses in condemnation proceedings to $50,000. The appellant, Applied Building Sciences, Inc., an engineering firm, was forced to move its operations when its leased building was condemned for public use by the South Carolina Department of Commerce, Division of Public Railways. The company sought reimbursement for reestablishment expenses exceeding $560,000 but was limited by state statute to $50,000. The company argued that the cap was unconstitutional under the Takings Clauses of the South Carolina and United States Constitutions. The court found that reestablishment expenses are separate from damages awardable as just compensation under both constitutions, thus upholding the constitutionality of the statutory cap. The court affirmed the lower court's granting of summary judgment in favor of the Department of Commerce, Division of Public Railways. View "Applied Building Sciences v. SC Dept of Commerce" on Justia Law

James Heyward was convicted of multiple crimes arising from the armed robbery, brutal beating, and murder of Alice Tollison during the burglary of her home. The South Carolina Supreme Court granted Heyward's petition for a writ of certiorari to address the trial court's refusal to remove Heyward's leg shackles during the striking of the jury, and four evidentiary issues. As to three of the evidentiary issues, the authentication of a fingerprint card, the admission of gruesome autopsy photographs, and the State's use of Heyward's alias, the Supreme Court found the trial court acted within its discretion. As to the other evidentiary issue, a firearms expert's testimony Heyward's pistol was operational at the time of the crimes, the Supreme Court affirmed the court of appeals' ruling that if there was any error in the admission of that testimony it did not prejudice Heyward. As to the leg shackles, the Court found the trial court erred in failing to exercise its discretion in determining whether Heyward should have been required to wear leg shackles in the presence of the jury. However, because the State conclusively proved Heyward's guilt through overwhelming evidence such that no rational conclusion could have been reached other than Heyward is guilty of these crimes, the Court nevertheless affirmed. View "South Carolina v. Heyward" on Justia Law

This appeal arose from a defense verdict in a case alleging law enforcement officers and the City of North Charleston violated the civil rights of Jane Doe, a vulnerable adult. During its deliberations, the jury submitted several questions, the last of which was ambiguous. The trial court answered the question without requesting clarification from the jury and denied Doe's request to charge the jury on nominal damages for a third time. The court of appeals affirmed. The South Carolina Supreme Court found the trial court erred in not requesting clarification, but ultimately concluded the error was harmless. The Court therefore affirmed the court of appeals in result. View "Estate of Jane Doe 202 v. City of North Charleston" on Justia Law

Corey Brown was convicted by jury of conspiracy to commit grand larceny, armed robbery, and kidnapping. In a post-trial motion, Brown moved for a new trial on several grounds, including the State's failure to disclose its negotiations with Shadarron Evans, the State's key witness. The trial court granted the motion, and the State appealed. Agreeing with the State, the court of appeals reversed the grant of a new trial, concluding that no plea offer had been extended and remanded the case to the circuit court to make specific findings as to whether the evidence was material to Brown's guilt under Brady v. Maryland, 373 U.S. 83 (1963). The South Carolina Supreme Court granted Brown's petition for a writ of certiorari to review the decision of the court of appeals. After that review, the Supreme Court reversed and remanded the case to the circuit court for a new trial. View "South Carolina v. Brown" on Justia Law

Petitioner Robert Miller, III was convicted of murdering eighty-six-year-old Willie Johnson. Following the murder, Petitioner—who was fifteen years old at the time—confessed four times: twice to his close friends and twice to law enforcement. All four confessions were admitted at trial, three without objection. This appeal centered around the voluntariness of Petitioner's fourth and final confession to two agents of the South Carolina Law Enforcement Division (SLED). After examining the totality of the circumstances surrounding the fourth confession, the South Carolina Supreme Court held that Petitioner's free will was not overborne, and his confession was voluntary. It therefore affirmed. View "South Carolina v. Miller" on Justia Law

The South Carolina Supreme Court issued a common-law writ of certiorari to review a "sealed" order of the circuit court reducing the prison sentence of Jeroid Price and releasing him from prison after he served only nineteen years of his thirty-five-year sentence on his murder conviction. The Court previously issued an order unsealing all documents in the case. Here, the Court vacated the order because: (1) the circuit court did not have the authority to reduce the sentence because the solicitor and the circuit court did not comply with any of the requirements set forth in the applicable statute; and (2) the circuit court did not have the authority to close the proceedings to the public or seal the order. The Court remanded Defendant to the custody of the South Carolina Department of Corrections. View "South Carolina v. Price" on Justia Law