South Carolina Supreme Court Opinions


On Wednesday, December 23rd, the South Carolina Supreme Court published three opinions: State v. Larmand, Grimsley v. Sled and State v. Drayton.

In State v. Lamand, the Court reversed the court of appeals’ decision in State v. Larmand, 402 S.C. 184, 739 S.E.2d 898 (Ct. App. 2013), and found that the State presented sufficient circumstantial evidence to overcome the defendant’s motion for a directed verdict.

In the employment case,  Grimsley v. Sled, the Court reverses the court of appeals, which reversed the trial court’s grant of summary judgment in favor of Petitioner SLED. The Court held that the trial court properly granted summary judgment to SLED because the record made clear that Respondents were rehired at reduced salaries and the employer contributions to the retirement system were not deducted from those salaries but were paid by SLED

In State v. Drayton, the Court reversed the court of appeals and held that the court of appeals erred in reaching the novel issue of whether the petitioner had an expectation of privacy in his historical cell site location data (HCSLD) because in view of the totality of the circumstances, the affidavits in support of the warrants established probable cause for the search. Additionally, the Court held that any error in the issuance of the warrants was harmless because petitioner’s guilt was conclusively established by other competent evidence at trial.

On December 9th, the South Carolina Supreme Court published two opinions: Cook v. State and Mack v. Lott.

In Cook v. State, the Court granted certiorari to determine whether the trial court erred in charging the jury with the lesser-included offense of voluntary manslaughter. The Court reversed Petitioner’s conviction for voluntary manslaughter, finding no evidence to support he acted in the sudden heat of passion.

In Mack v. Lott, the Court directs the appellate court to depublish its prior opinion  in Mack v. Lott, 410 S.C. 28, 762 S.E.2d 719 (Ct. App. 2014). The Court then dismisses the writ as improvidently granted.

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