Justia South Carolina Supreme Court Opinion Summaries

A group of retired firefighters and police officers who worked for the City of Columbia all elected to have group health insurance provided to them by the city. Prior to July 2009, the City paid all costs to fund the group health insurance for employees and retirees. The retirees received newsletters stating that their health insurance was free and were told by the City's human resources department that retiree health insurance would be at no cost to the retiree. In planning the 2009-2010 budget, the City considered a number of cost-saving measures including shifting part of rising health care costs to participants in the group health plan. The retirees sued under claims of breach of contract, promissory estoppel, and equitable estoppel. The circuit court granted summary judgment in favor of the City on the retirees' causes of action. Seven of the thirteen retirees appealed that decision. Upon review, the Supreme Court found that the trial court properly granted summary judgment against the retirees on their contract and estoppels claims to the extent that those claims were based on an employee handbook and benefits booklet each received when they were hired. However, the Court found that the trial court erred in granting summary judgment against the retirees on their estoppel claims based upon representations made by their supervisors and the City's human resources personnel. View "Bishop v. City of Columbia" on Justia Law

Appellant Jarmel Rice was charged as a juvenile when he was fifteen years old for a series of violent crimes. Following a contested waiver from family court to general sessions court, Appellant pled guilty to three counts of armed robbery and one count of assault with intent to kill and received a sentence of eleven years in prison, with many other charges dismissed. In pleading guilty, Appellant raised no objection to the family court waiver. On appeal to the Supreme Court, Appellant sought to resurrect his family court constitutional challenge to the waiver as violative of "Apprendi v. New Jersey," (530 U.S. 466 (2000)). Because South Carolina permits only unconditional guilty pleas and no jurisdictional claim was presented, the Supreme Court concluded Appellant waived his right to assert a claim based on "Apprendi.": "[b]eyond Appellant's failure to assert a jurisdictional argument on appeal . . . Appellant's Apprendi challenge fails on the merits." The Court held that Apprendi is not applicable to a family court juvenile waiver hearing, for a decision whether to waive a juvenile to general sessions court in no manner determines the juvenile's guilt, innocence, or punishment - it merely determines the forum in which the case is to be tried. View "South Carolina v. Rice" on Justia Law

Appellant Derrick Cheeks was convicted of trafficking in crack cocaine in excess of 400 grams and possession of crack with intent to distribute within proximity to a school and received concurrent sentences of twenty-five years (trafficking) and ten years (proximity). On appeal, he contended the trial court erred in failing to find a search warrant fatally defective, and in giving an improper jury instruction. Upon review, the Supreme Court found no merit in the warrant issue, but agreed the instruction was improper. Because the Court found appellant was not prejudiced by the erroneous charge, the Court affirmed his convictions and sentences. View "South Carolina v. Cheeks" on Justia Law

The State appealed the court of appeals' decision which held that the police search and seizure of Respondent Sylvester Taylor was improper under the Fourth Amendment to the United States Constitution. Respondent was indicted for possession with intent to distribute crack cocaine. The case proceeded to trial, and the sheriff's deputy that conducted the search testified in camera regarding the discovery of the crack cocaine. Respondent was found guilty and sentenced, as a third-time drug offender, to thirty years' imprisonment. The court of appeals overturned the conviction, finding that police did not have reasonable suspicion to stop Respondent. Upon review of the trial court record, the Supreme Court held that the court of appeals erred in finding that police did not have reasonable suspicion to justify an investigatory stop of Respondent. View "South Carolina v. Taylor" on Justia Law

In a direct appeal to the Supreme Court, Appellant Dunes West Golf Club, LLC, challenged the trial court's grant of summary judgment in favor of Respondent Town of Mount Pleasant. In 2006, the Town of Mount Pleasant amended its zoning ordinance to create the Conservation Recreation Open Space zoning district, which imposed land-use restrictions on all golf course properties in Mount Pleasant, permitting only recreation and conservation uses. Appellant desired to carve out residential lots on its golf course property by designating several noncontiguous parcels as potential home sites. Because the new zoning designation did not permit construction of new homes, Appellant sought to have the golf course property rezoned to allow residential development. The Town denied the rezoning request, and Appellant filed suit, claiming the Town's actions violated its equal protection and due process rights, and amounted to an unconstitutional taking of its property. Following discovery, the Town of Mount Pleasant successfully moved for summary judgment. The Court carefully reviewed each assignment of error and found summary judgment was properly granted. View "Dunes West v. Town of Mount Pleasant" on Justia Law

Defendant Danny Cortez Brown was convicted of trafficking in cocaine and sentenced to twenty-five years in prison. He appealed, arguing the trial court erred in denying his motion to suppress the cocaine, which was seized from a duffel bag after his arrest for an open container violation during an automobile stop. The Court of Appeals reversed on the basis the search was improper under "Arizona v. Gant," (556 U.S. 332 (2009)). Upon review, the Supreme Court concluded that the Court of Appeals properly applied "Gant" and found the warrantless police search conducted incident to Defendant's arrest for an open container violation was illegal. Furthermore, the Court held that pursuant to the United States Supreme Court's subsequent pronouncement in "United States v. Davis," (131 S. Ct. 2419 (2011)) that the exclusionary rule was not applicable to this case because the officer relied upon existing appellate precedent at the time he conducted his search. Consequently, the decision of the Court of Appeals was reversed. View "South Carolina v. Brown" on Justia Law

In a declaratory judgment action, the parties appealed the circuit court's order authorizing Storm M. H. ("Student"), who resided in Berkeley County, to enroll in the Academic Magnet High School ("AMHS") located in the Charleston County School District ("CCSD") provided she purchase real property in the CCSD with a tax-assessed value of $300 or more. Student resided with her parents in Berkeley County. In January 2010, she applied for admission to the 9th grade class at the AMHS for the following academic year. In her application, Student identified her Berkeley County address. Student was accepted by the AMHS and required to confirm her intention to enroll by January 28, 2010. The Confirmation Form requested a "Charleston County Residence Address." After seeing this request, Student's mother, Gayla S. L. McSwain ("Parent"), spoke with someone at the AMHS and explained that Student could not provide a Charleston County address because she did not "live in Charleston County yet." As a result of this conversation, Parent completed the Confirmation Form by indicating that she would "provide [a Charleston County residence address] prior to enrollment." The circuit court held that the CCSD's policy of requiring domicile for a child to attend a CCSD magnet school violated section 59-63-30(c) because "domicile" by a child and that child's parent or guardian was not required by the statute only property ownership. Both parties appealed the circuit court's order to the court of appeals. Subsequently, Student purchased real property in Charleston County and enrolled in the AMHS on August 18, 2010. Upon review, the Supreme Court concluded that CCSD's policy of excluding all non-resident children from attendance at its magnet schools was contrary to the plain language of section 59-6330, and the Student was entitled to continue attending AMHS. "We are not unsympathetic to the Board's argument that allowing non-resident children to attend its magnet schools displaces other qualified resident children. However, we are constrained to interpret the unambiguous language of section 59-63-30. . . . As the statute is written, the Board does not have the authority to unilaterally exclude children who qualify to attend its schools." View "Storm M. H. v. Charleston County Board of Trustees" on Justia Law

The Supreme Court accepted the petition of Harleysville Mutual Insurance Company (Petitioner) in its Original Jurisdiction to assess constitutional challenges to Act No. 26 of the South Carolina Acts and Joint Resolutions, which regulates coverage provided by commercial general liability (CGL) insurance policies for construction-related work. Upon review, the Supreme Court held that the retroactivity clause of Act No. 261 violated the Contract Clauses of the state and federal Constitutions, and that the statute may only apply prospectively to CGL insurance contracts executed on or after its effective date of May 17, 2011. View "Harleysville Mutual v. South Carolina" on Justia Law

This case returns to the Supreme Court on remand from the United States Supreme Court (USSC) for reconsideration in light of its decision in "Williamson v. Mazda Motor of America, Inc.," (131 S.Ct. 1311 (2011)). In the South Carolina Court's previous decision, it concluded Appellant's state-law products liability claims against Ford Motor Company were preempted by Federal Motor Vehicle Safety Standard ("FMVSS") 205. The Court reaffirmed its previous decision. Appellant filed a products liability claim against Respondent Ford Motor Company premised on the allegation that its 1997 Ford F-150 pick-up truck was defective and unreasonably dangerous because it did not incorporate laminated glass in the vehicle's side and rear windows. In connection with implied conflict preemption, "Williamson" revisited the Supreme Court's decision in "Geier v. American Honda Motor Co.," (529 U.S. 861 (2000)). "We construe the key language in Williamson to hold that manufacturer choice among alternatives operates to preempt a state law claim only where the state law stands as an obstacle to a significant federal regulatory objective. Similarly, our previous decision was not based upon the notion that the mere presence of manufacturer choices in FMVSS 205 preempted Appellant's state tort suit. We adhere to the view that the manifest purpose of the federal regulatory scheme underlying FMVSS 205 would be frustrated if these state claims were allowed to proceed. Assuming implied conflict preemption remains a viable part of preemption, we believe it applies here to preclude Appellant's state law claims." View "Priester v. Cromer" on Justia Law

The issue before the Supreme Court in this case was whether Section 1-7-330 of the South Carolina Code (2005), which vested control of the criminal docket in the circuit solicitor, violated the separation of powers principle embodied in Article 1, Section 8 of the South Carolina Constitution. In 1980, the Court recognized that "[t]he authority of the court to grant continuances and to determine the order in which cases shall be heard is derived from its power to hear and decide cases. . . .This adjudicative power of the court carries with it the inherent power to control the order of its business to safeguard the rights of litigants." The Court concluded that section 1-7-330 was at odds with "this intrinsically judicial power." The Court therefore held that section 1-7-330 violated the separation of powers and therefore was unconstitutional. However, because Appellant K.C. Langford, III suffered no prejudice as a result of section 1-7-330, the Court affirmed his convictions. View "South Carolina v. Langford" on Justia Law