Justia South Carolina Supreme Court Opinion Summaries

Tyrone Wallace Jr. appealed his convictions for murder and kidnapping, challenging the trial court's ruling that a witness who placed Wallace's phone near the two crime scenes based on cell site location information (CSLI) was "qualified as an expert by knowledge, skill, experience, training, or education" under Rule 702 of the South Carolina Rules of Evidence. The court of appeals affirmed. The South Carolina Supreme Court granted Wallace's petition for a writ of certiorari to address only this issue. The Court found the trial court acted within its discretion, and affirmed the judgment. View "South Carolina v. Wallace" on Justia Law

The Kitchen Planners, LLC, filed a petition for a writ of certiorari asking the South Carolina Supreme Court to review the court of appeals' decision in Kitchen Planners, LLC v. Friedman, 851 S.E.2d 724 (Ct. App. 2020). In that decision, the court of appeals affirmed the circuit court's order granting summary judgment to the Friedmans and dissolving Kitchen Planners' mechanic's lien. The Supreme Court granted Kitchen Planners' petition in part and affirmed as modified: the court of appeals incorrectly applied the wrong standard of decision for a motion for summary judgment when the motion was based on insufficiency of the evidence. Reviewing the circuit court's order using the correct standard of decision, however, the Court nevertheless found the court of appeals reached the correct result in affirming the summary judgment. View "The Kitchen Planners v. Friedman" on Justia Law

In 2023, a majority of the South Carolina Supreme Court found unconstitutional the 2021 version of the Fetal Heartbeat and Protection from Abortion Act (the 2021 Act). In response to its decision, the South Carolina General Assembly (the legislature) revised the 2021 Act, especially in terms of its legislative findings and purposes, and passed a new version of the Fetal Heartbeat and Protection from Abortion Act (the 2023 Act). Immediately after the Governor signed the 2023 Act into law, Planned Parenthood South Atlantic and three other medical providers (collectively, Planned Parenthood) filed an action in the circuit court seeking a declaration that the new law was unconstitutional. Upon Planned Parenthood's motion, the circuit court enjoined enforcement of the 2023 Act pending resolution of the constitutional challenge. Numerous state officials (collectively, the State) promptly filed an emergency petition to the South Carolina Supreme Court for supersedeas or, alternatively, a request that it accept the matter in its original jurisdiction and expedite briefing. The Court denied the petition for supersedeas but granted the alternative request to accept the matter in its original jurisdiction and expedite resolution of the case. The Court vacated the preliminary injunction issued by the circuit court and declared the 2023 Act constitutional. View "Planned Parenthood South Atlantic, et al. v. State of South Carolina, et al." on Justia Law

Charles Dent was convicted and sentenced on one count of first-degree criminal sexual conduct (CSC) with a minor and two counts of disseminating obscene material to a minor. Dent appealed, and a divided court of appeals' panel reversed and remanded for a new trial, finding the trial court erred in failing to give the requested circumstantial evidence charge the South Carolina Supreme Court articulated in State v. Logan, 747 S.E.2d 444 (2013). Because this ruling was dispositive, the court of appeals did not reach Dent's other assignments of error. The Supreme Court granted the State's petition for a writ of certiorari and then reversed: while the Court agreed with the court of appeals' finding of error in the trial court's failure to charge circumstantial evidence pursuant to Logan, the error was harmless. The Court reversed and remanded to the court of appeals for consideration of Dent's remaining issues on appeal. View "South Carolina v. Dent" on Justia Law

A jury found Petitioner Carmie Nelson ("Carmie") guilty of murdering her roommate, and the trial court sentenced her to life imprisonment. Carmie appealed, arguing, among other things, that the trial court erred in admitting gruesome autopsy photos in contravention of Rule 403, SCRE. The court of appeals, finding no error, affirmed in an unpublished opinion. The South Carolina Supreme Court granted Carmie's petition for a writ of certiorari, and reversed: “the photos admitted here surpassed ‘the outer limits of what our law permits a jury to consider.’” View "South Carolina v. Nelson" on Justia Law

The United States District Court for the District of South Carolina certified a question of law to the South Carolina Supreme Court. Plaintiff John Doe was a convicted sex offender who moved from South Carolina to Georgia in 2015. He filed suit in South Carolina in federal court against the Chief of the South Carolina Law Enforcement Division (SLED) Mark Keel, contending in part that because he no longer resided in South Carolina, SLED should be prohibited from continuing to publish his name and information on the South Carolina Sex Offender Registry. The question certified to the Supreme Court involved whether South Carolina’s Sex Offender Registry Act (SORA) permitted the publication of out-of-state offenders on the state’s public sex offender registry. The Supreme Court answered the question in the affirmative. View "John Doe v. Keel" on Justia Law

Petitioners Rick Hendrick Dodge Chrysler Jeep Ram (Rick Hendrick Dodge) and Isiah White argued an arbitrator had to decide whether they could enforce an arbitration provision in a contract even after that contract had been assigned to a third party. The court of appeals rejected this argument and affirmed the circuit court's determinations that: (1) the circuit court was the proper forum for deciding the gateway question of whether the dispute is arbitrable; and (2) Petitioners could not compel arbitration because Rick Hendrick Dodge assigned the contract to a third party. The South Carolina Supreme Court held that the doctrine announced in Prima Paint Corp. v. Flood & Conklin Mfg. Co., 388 U.S. 395 (1967) required the arbitrator to decide whether the assignment extinguished Petitioners' right to compel arbitration. Therefore, the Court reversed the court of appeals' decision and vacated the circuit court's discovery order. View "Sanders v. Savannah Highway Automotive Company" on Justia Law

Respondent John Perry, Jr. was convicted by jury of the attempted murder of a police officer. During deliberations, the jury requested a recharge on intent. Over the defense's objection, the trial court instructed, "When the intent to do an act that violates the law exists motive becomes immaterial." The court of appeals reversed and remanded for a new trial, concluding the statement improperly instructed the jury on general intent for the crime of attempted murder. While the South Carolina Supreme Court agreed that the trial court erred in giving the jury this recharge, the Supreme Court believed the error was harmless. Accordingly, it reversed the decision of the court of appeals. View "South Carolina v. Perry" on Justia Law

The South Carolina Court of Appeals affirmed Petitioner Tappia Green's convictions for kidnapping, armed robbery, and possession of a weapon during the commission of a violent crime. During an in camera hearing, the parties offered competing evidence as to whether Green was given his Miranda warnings, with law enforcement officers claiming they did not Mirandize Green at the time of his arrest and Green asserting they did. The trial court found the State's evidence more credible, determining Green was not Mirandized and, therefore, a violation of Doyle v. Ohio, 426 U.S. 610(1976) did not occur. As a result, the trial court denied Green's motion for a mistrial. Nevertheless, the State did not further pursue Green's post-arrest silence. The court of appeals affirmed, focusing on the novel question of whether the State or the defendant had the burden of proof in a Doyle hearing and, ultimately, concluding the defendant had the burden to prove Miranda warnings were given and a Doyle violation occurred. The South Carolina Supreme Court took the opportunity of this case to clarify the proper procedure when a potential Doyle violation arises. "Care must be taken when the State seeks to impeach a defendant with his post-arrest silence." As the proponent of such impeachment evidence, the Court held the State bears the burden of proving the evidence is admissible and will not violate the defendant's right to due process as articulated in Doyle and its progeny. "In its role as the gatekeeper of admissibility, the trial court must evaluate the evidence and determine whether the State has shown by a preponderance of the evidence that the defendant was not given his Miranda warnings." Here, the Court found the trial court properly fulfilled its role and issued a detailed ruling supported by a number of facts in evidence. The Court therefore held the trial court did not commit error in denying Green's motion for a mistrial. The decision of the court of appeals was affirmed as modified and vacated in part. View "South Carolina v. Green" on Justia Law

Petitioner Anthony Jones pleaded guilty to first-degree burglary and armed robbery, crimes he committed at the ages of sixteen and seventeen, respectively. Pursuant to subsection 63-19-20(1), South Carolina's definitional statute of chapter nineteen in the Juvenile Justice Code, the circuit court had jurisdiction over Jones's charges, rather than the family court. The circuit court judge sentenced Jones to ten years in prison for armed robbery and fifteen years for first-degree burglary, with the sentences to run concurrently. Jones did not file a direct appeal. Instead, he filed an application for post-conviction relief ("PCR") on several grounds, including a challenge to the constitutionality of subsection 63-19-20(1). After a hearing, the PCR court dismissed the application, finding the constitutional challenge was not a cognizable PCR claim and, even if it were, the statute was constitutional. The South Carolina Supreme Court concluded Jones properly brought this challenge in his PCR application and subsection 63-19-20(1) was constitutional. However, in keeping with prior decisions regarding sentencing juveniles, the Court held circuit court judges had to consider the mitigating factors of youth as identified in Aiken v. Byars when sentencing. "Consideration of these factors can be done at sentencing; therefore, a separate Aiken hearing is not required." Accordingly, the Supreme Court affirmed in part and reversed in part. View "Jones v. South Carolina" on Justia Law