Justia South Carolina Supreme Court Opinion Summaries

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

Daufuskie Island Utility Company (DIUC) again appealed decisions by the Public Service Commission (PSC) regarding DIUC's 2015 application for ratemaking. In the PSC's first two decisions, it granted only part of the 109% rate increase requested by DIUC. DIUC appealed both decisions, and both times, the South Carolina Supreme Court reversed and remanded to the PSC for further consideration. On the final remand, the parties entered a settlement agreement allowing DIUC to recover rates equivalent to the 109% rate increase it initially requested in 2015. However, the parties continued to disagree over the propriety of DIUC's additional request to retroactively recover the 109% rate increase from the date of the PSC's first order, rather than from the date of the PSC's acceptance of the settlement agreement. The PSC rejected DIUC's request for the "reparations surcharge," finding it would amount to impermissible retroactive ratemaking. The propriety of the reparations surcharge was the only matter at issue in this appeal. The Supreme Court found the General Assembly did not authorize the PSC to grant utilities relief via a reparations surcharge, and the PSC therefore correctly rejected DIUC's request. The Court found DIUC chose not to avail itself of South Carolina Code section 58-5-240(D)'s statutory remedy prior to this final appeal. Accordingly, the PSC's decision was affirmed and the Court "end[ed] this lengthy ratemaking process." View "Daufuskie v. SC Office of Regulatory Staff" on Justia Law

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