Justia South Carolina Supreme Court Opinion Summaries

Appellant Essie Simmons and Respondent Rubin Simmons divorced in 1990. The parties entered into a settlement agreement that was approved by the family court. Central to the agreement was the requirement that Mr. Simmons give Ms. Simmons a half or third of his Social Security benefits, depending on his age when he retired. When he retired, Mr. Simmons did not pay his ex-wife. She sued, but the family court declined to hear the complaint, finding that it could not hear a case that primarily dealt with Social Security benefits. Mr. Simmons appealed the dismissal, and the appellate court reversed. The court voided the division of Mr. Simmons' benefits, holding that the Social Security Act specifically precluded parties from dividing benefits under the settlement agreement. Because the agreement was partly voided by the court, Ms. Simmons sought to reopen the matter entirely. The family court dismissed again, holding that it lacked jurisdiction to revisit the agreement. On appeal, the Supreme Court was presented with the question of whether the family court could revisit the now partially voided agreement. Upon careful review of the arguments and applicable legal authority, the Court held that "basic principles of equity suggest[ed] that all issues should be revisited by the family court." The Court recognized the practical difficulties confronting the family court, but the Court noted, "that challenge pales in comparison to [Mr. Simmons'] suggestion that we simply end this matter with the remnant of the agreement remaining valid." The Court reversed the decision of the lower court and remanded the case to the family court for further proceedings. View "Simmons v. Simmons" on Justia Law

The State appealed a circuit court order dismissing its case against Respondent Gregory Duncan. Respondent was indicted for murder after he shot and killed Christopher Spicer at his home. The court ruled that Respondent was immune from prosecution under the state Protection of Persons and Property Act. The Supreme Court found that the trial record reflected ample evidence to support the circuit court's ruling. The Court affirmed the circuit court's decision to dismiss the State's case. View "South Carolina v. Duncan" on Justia Law

Appellant Kenneth Justus was sentenced to death for the murder of Justin Bregenzer. On appeal to the Supreme Court, Appellant argued that the trial court abused its discretion when it disqualified one of his two appointed counsel. The counsel in question, Maite Murphy, had worked for the State's lead investigator as a divorce attorney. The trial court removed Ms. Murphy as Appellant's trial counsel, holding that that a former business relationship presented a conflict-of-interest issue. Upon careful consideration of the arguments and the applicable legal authority, the Supreme Court affirmed the lower court's decision to remove Appellant's counsel. View "South Carolina v. Justus" on Justia Law

This case involves the State's "working retiree program," and the propriety of its withholding retirement contributions from eligible members who returned to work with the state prior to July, 2005. Before that time, the program allowed employees to retire, then after a break, be re-hired and receive retirement benefits and a salary of up to $50,000 per year without having to pay into the pension plan. The State was ordered to refund any contributions made since July, 2005 by program members. In 2005, the State Retirement System Preservation and Investment Reform Act amended the program to require retired members pay the employee contribution as if they were active members but without accruing additional service credit. The State appealed the circuit court's order to refund the contributions. The retirees challenged the change in the program, arguing that it was unlawful for the State to change the terms of the working retiree program after the retirees "irreversibly retired" with the understanding that contributions to the pension plan would not be required. Upon careful consideration of the arguments and legal authority, the Supreme Court reversed the circuit court's holding with respect to the State's return of contributions since 2005. The Court found that the Legislature enabled the State to take the contributions when it amended the program by Act in 2005. The Court dismissed the Retirees' challenge to the State Retirement System Preservation and Investment Reform Act, finding no merit in their argument. View "Ahrens v. South Carolina" on Justia Law

Appellants South Carolina Department of Corrections (SCDC) and three of its officers appealed a circuit court order enjoining them from forwarding certain information regarding Respondent James Compton to the Department of Probation, Parole and Pardon Services (DPPPS). Respondent committed burglary, assault and battery, armed robbery and aggravated assault and battery in South Carolina. He fled to Georgia, but was apprehended there a short time later. Respondent voluntarily returned to South Carolina where he was prosecuted, found guilty, and sentenced to life plus forty-five years' imprisonment. In 1982, Respondent was "away without leave" (AWOL) for a period of time. No charges were filed against him when he returned. In 1995, Respondent went AWOL again, but he was not returned to custody until 2002. An arrest warrant and indictment were issued on escape charges, but they were "nol prossed" when the State failed to appear before the grand jury. The circuit court issued an order in 2005 for the destruction of the arrest warrant and indictment in connection with the 1995 incident. Respondent's criminal history still referenced the 1995 charges. Respondent was not granted parole because questions regarding the 1995 escape charges persisted at DPPPS hearings. Respondent petitioned the court for a declaration that SCDC failed to comply with the court order to destroy records of his 1995 escape charges. The court found that SCDC was not in willful violation of the court orde, and that the entries were in Respondent's criminal history for security and classification purposes. The court enjoined the SCDC from forwarding information regarding the 1995 escape to DPPPS. SCDC argued on appeal to the Supreme Court that the circuit court erred in granting Respondent an injunction. Upon review, the Supreme Court reasoned that "a prisoner absenting himself from a prison (commonly referred to as an escape) is a fact that exists regardless of whether charges are filed in connection with it ... Because the injunction we affirm only enjoins the dissemination of records pertaining to criminal charges and not historical facts, [SCDC] is not enjoined from forwarding information they have a duty to send to DPPPS." Accordingly, the Court affirmed the lower court's decision. View "Compton v. South Carolina Dept. of Corrections " on Justia Law

Craig Reeves was the biological father of "Baby Boy Roe." The biological mother of the child was sixteen when she found out she was pregnant. She attempted to include Mr. Reeves in the pregnancy from the onset, but he was dating another woman, and the record reflected he clearly was not interested in becoming a parent. The mother contacted an adoption agency about placing the child up for adoption and settled on Appellants "John and Jane Roe." At some point, the mother began to have reservations over her decision to give the baby up for adoption. At some point, Mr. Reeves had a change of heart over his involvement with the mother and her pregnancy. He bought some diapers and periodically bought things for the mother, but nothing to the extent that Appellants had done. the father lived with his parents, and converted some extra space in his home as a makeshift "nursery," fully expecting to take the baby home with him once it was born. Mr. Reeves went to the hospital to see "his" son when born, but the hospital informed him that the mother was a "no information" patient, and he was turned away. The next day, the mother signed an adoption consent form, and Appellants took the child home. Mr. Reeves brought suit in family court, arguing that the baby could not be adopted without his consent. The court found that his consent was needed, and ordered the child be returned to his custody. Upon review, the Supreme Court found that Mr. Reeves "did not fully grasp the opportunity to come forward and demonstrate a full commitment to the responsibilities of parenthood through prompt and good faith efforts." The Court held that Mr. Reeves' contributions were not sufficient compliance with state law to establish his right to consent to the adoption. The Court reversed the family court order pertaining to the father's consent, and awarded immediate custody of the child to Appellants. View "Roe v. Reeves" on Justia Law

Petitioner Terrance Edwards appealed a circuit court order that denied him post conviction relief. Petitioner was indicted for murder, robbery, and grand larceny. On appeal to the Supreme Court, Petitioner alleged that his attorney was ineffective for failing to interview a witness whose testimony could have exonerated him. Testimony by Petitioner's trial counsel revealed that it was a strategic decision not to interview the witness. The lower court determined that Petitioner failed to establish any resulting prejudice from his attorney's actions. Upon review of Petitioner's arguments, the trial record and the applicable legal authority, the Supreme Court found probative evidence to support the lower court's conclusion. The Court dismissed petitioner's application for post conviction relief and affirmed the lower court's decision. View "Edwards v. South Carolina" on Justia Law

Petitioner Najjar Byers unsuccessfully appealed the circuit court's denial of his motion to strike a witness' testimony at trial. On an evening in June 2005, a bingo hall was robbed at gunpoint. Police stopped a car after noticing its occupants were not wearing seat belts. Petitioner was a passenger in the car, along with three others. The driver gave police permission to search the car. Police found a cash register till, two handguns and two ski masks. The officer then received a bulletin from his radio that police were looking for a vehicle that matched the description of the car he had just pulled over. The officer took the car's occupants into custody. Petitioner was the only sober occupant at the time of the arrest. The key issue in this case was whether or not Petitioner was a passenger in the car at the time of the robbery. At trial, the State presented contradictory testimony from two of the other occupants. When defense counsel examined the other occupants, they testified they were either too drunk or too high to remember whether Petitioner was in the car. Petitioner moved to strike testimony by the occupants that he was in the car which was denied. Petitioner moved for a directed verdict at the close of the State's evidence that was also denied. On appeal to the Supreme Court, Petitioner argued that the trial and appellate courts erred in convicting him based on the evidence presented at trial. "With the greatest respect for the learned opinion of the court of appeals," the Supreme Court could "not understand the basis for its conclusion." The Court concluded, "another rational conclusion could have been reached by the jury." The Court reversed Petitioner's conviction. View "South Carolina v. Byers" on Justia Law

Appellant Don Phillips was the sole shareholder and officer in Crystal Lake Land Developers, Inc.(CLLD). In 1979, CLLD began developing Crystal Pines, and deeded all the roads in Crystal Pines to the Crystal Lake Road Company. In the mid 1980s, the Road Company operated as a simple homeowners association, but eventually changed its name to Crystal Pines Homeowners Association (HOA). CLLD attempted to execute a second deed to reflect the change of the Road Companyâs name to the HOA. The second deed stated that the HOA would be responsible for fixing the roads in Crystal Pines. In 1980, CLLD constructed a boat ramp that many of the homeowners used regularly. In 2004, CLLD gated and locked the boat ramp, and later conveyed title of the ramp to his son. The son then transferred title of the ramp to the Crystal Pines Yacht Club, which continued to keep the ramp locked from the residents. The HOA filed suit against Phillips, CLLD and the Yacht Club over who was responsible for maintaining Crystal Pinesâ roads, and for access to the boat ramp. The master-in-equity ruled in favor of the HOA, and Phillips, CLLD and the Yacht Club appealed. The Supreme Court found the deed in question unambiguous pertaining to who was responsible for fixing the roads. The Court found that CLLD and Phillips are not responsible for maintaining all of Crystal Pinesâ roads, only those roads they damage as a result of their development efforts. However, the Court found the mater did not err in finding that the HOA had established a prescriptive easement in its use of the boat ramp. The Court affirmed part and reversed part of the lower courtâs decision, and remanded the case for further proceedings on that which it reversed.

AnMed Health admitted liability to Respondent Elise Burke stemming from a trial held in 2005. Respondent was injured from a preoperative procedure, and the jury awarded her $250,000 in damages. AnMed appealed the verdict, arguing that the trial court made several mistakes in the proceedings, which ultimately entitled it to a new trial. Specifically, AnMed looked to the state's "thirteenth juror" doctrine which allowed a trial court to grant a new trial if it determined the jury verdict was "contrary to the fair preponderance of the evidence." The Supreme Court conceded that the thirteenth juror doctrine grants a trials court very broad discretion in determining whether a new trial is warranted, and the Court agreed that the jury verdict in this case was "generous." However, the Court found the trial judge's ruling to deny AnMed's motion for a new trial was within his discretion, and affirmed the lower court's decision.