Justia Constitutional Law Opinion Summaries

The case involves a challenge to the constitutionality of the 2023 Act No. 8 (S. 39), known as the Education Scholarship Trust Fund (ESTF) Act, which establishes a fund to provide scholarships for qualifying educational expenses, including private school tuition. Petitioners argue that the Act violates South Carolina's constitutional prohibition against using public funds for the direct benefit of private educational institutions.The lower courts did not review this case; it was accepted directly by the South Carolina Supreme Court in its original jurisdiction. Petitioners sought an injunction and declaratory judgment, claiming the Act violated several provisions of the South Carolina Constitution, including Article XI, Sections 2, 3, and 4, and Article X, Sections 5 and 11.The South Carolina Supreme Court held that portions of the Act violate the state constitution's prohibition against using public funds for the direct benefit of private educational institutions. The court found that the ESTF funds are public funds and that using these funds for private school tuition constitutes a direct benefit to private educational institutions, which is unconstitutional under Article XI, Section 4. The court severed and declared unconstitutional the provisions of the Act that allowed payments from ESTF scholarships for tuition and fees at private educational institutions. The court enjoined the Department of Education from disbursing ESTF scholarships for these purposes. The court's decision was guided by the principle that legislative policy must conform to constitutional mandates, and it emphasized the importance of adhering to the plain meaning of constitutional text. View "Candace Eidson v. South Carolina Dept. of Education" on Justia Law

Four condemned inmates challenged the constitutionality of a South Carolina statute that provides three methods of execution: electrocution, lethal injection, and firing squad. They argued that the statute violates the South Carolina Constitution's prohibition against cruel, corporal, or unusual punishment.The Richland County Circuit Court ruled in favor of the inmates, declaring the statute unconstitutional. The court found that electrocution and firing squad methods violate the state constitution's prohibition on cruel, corporal, or unusual punishment. It also found the statute's provision allowing inmates to choose their method of execution unconstitutionally vague and an improper delegation of authority. The court further ruled that the retroactive application of the amended statute violated ex post facto prohibitions.The South Carolina Supreme Court reversed the lower court's decision. The court held that the statute does not violate the South Carolina Constitution. It found that electrocution is not unconstitutionally cruel, corporal, or unusual, noting that the inmates did not meet their burden of proving that electrocution causes unnecessary and excessive pain. The court also held that lethal injection, as conceded by the inmates, is constitutional if properly administered. Regarding the firing squad, the court found it to be a relatively quick and painless method of execution, thus not cruel or unusual.The court also addressed the inmates' claims about the statute's vagueness and improper delegation of authority, finding that the term "available" is not unconstitutionally vague and that the statute does not unlawfully delegate authority to the Director of the Department of Corrections. The court emphasized that the statute's provision allowing inmates to choose their method of execution is a constitutional innovation aimed at making the death penalty less inhumane. The court concluded that the statute is constitutional in its entirety. View "Owens v. Stirling" on Justia Law

Orthofix, Inc. and KCI USA, Inc., both Delaware corporations with principal places of business outside South Carolina, sold durable medical equipment (DME) in South Carolina and remitted the 6% sales tax without protest. However, they later requested refunds for the sales tax paid during certain periods, arguing that they should qualify for a sales tax exemption for DME paid for by Medicaid or Medicare funds. This exemption, however, was only available to sellers whose principal place of business was in South Carolina. The South Carolina Department of Revenue (DOR) denied the refund claims, stating that the companies did not meet the statutory requirements for the exemption.The companies appealed the decisions within the DOR, arguing that the exemption's limitation to in-state businesses violated the dormant Commerce Clause of the U.S. Constitution. The DOR issued determinations finding that the companies were not entitled to a refund of sales tax paid for DME. The companies then filed actions in the circuit court challenging the constitutionality of the exemption under the dormant Commerce Clause. The circuit court granted summary judgment to each company, finding the exemption's discrimination against interstate commerce unconstitutional and severing the "principal place of business in South Carolina" requirement from the remainder of the exemption.The South Carolina Supreme Court affirmed the circuit court's decision as modified. The court agreed that the exemption unconstitutionally discriminated against interstate commerce in violation of the dormant Commerce Clause and that the ordered refunds were appropriate. However, the court found that the companies had not satisfied their burden of proof to show the legislature would have passed the remainder of the exemption absent the unconstitutional language. Therefore, the court declined to sever only the offending language and instead declared the entire exemption void going forward. The court invited the legislature to reenact the exemption, excluding the unconstitutional limitation on a seller's principal place of business. View "Orthofix v. South Carolina Department of Revenue" on Justia Law

Eric English was convicted of first-degree criminal sexual conduct with a minor, his biological daughter. The victim, who was six or seven years old at the time of the abuse, tested positive for gonorrhea. English and Jamie Stroman, the victim's mother's boyfriend, also underwent STD testing. English tested positive for gonorrhea, while Stroman tested negative. The trial court admitted the STD test reports as evidence under the business records exception to the rule against hearsay, despite English's objections.The court of appeals affirmed the trial court's decision, arguing that the test reports were admissible under the business records exception and were not testimonial under the United States Supreme Court's holding in Davis v. Washington. English appealed, arguing that the test reports were inadmissible without the testimony of the individuals who performed the tests, citing State v. James.The Supreme Court of South Carolina affirmed the lower courts' decisions in part and vacated in part. The court overruled James, stating that it had been abrogated by subsequent decisions interpreting the Sixth Amendment's Confrontation Clause. The court held that the STD test reports were nontestimonial and did not implicate English's Sixth Amendment right of confrontation. Therefore, the trial court did not err in admitting the reports without requiring the testimony of the individuals who authored the reports. However, the court vacated the court of appeals' holding that the requirements of Rule 803(6) were satisfied, as English did not argue that the reports did not meet these requirements. View "The State v. English" on Justia Law

In July 2018, Thomas Jones was observing a traffic stop conducted by two deputies outside his home. Jones interacted with the deputies, asking questions about the stop. The deputies responded by arresting Jones, using a taser in the process. Jones was convicted under a Greenville County ordinance for interfering with a county law enforcement officer. He was sentenced to thirty days in jail and a $1,000 fine, which was suspended upon ten days in jail over weekends and a $500 fine. Jones appealed his conviction, arguing that the ordinance was unconstitutionally applied to him and that the ordinance itself was unconstitutional under the First Amendment and the Due Process Clause of the United States Constitution.Jones's case was transferred to the Supreme Court of South Carolina due to the constitutional challenges he raised. The State conceded that the ordinance was improperly applied to Jones under the specific facts of the case and asked the court to reverse his conviction and sentence. The State also requested that the court not address Jones's broader challenges to the ordinance.The Supreme Court of South Carolina agreed with the State's position. The court noted that it generally declines to rule on constitutional issues unless necessary and that facial challenges to statutes are disfavored. The court found that Jones's actions of observing and asking questions were constitutionally protected conduct and could not support a conviction under the ordinance. The court was deeply disturbed by the deputies' behavior in this case but declined to go further than necessary in its ruling. The court reversed Jones's conviction on the narrow grounds that the ordinance was unconstitutionally applied to him and reserved judgment on the broader challenges to the ordinance for another case. View "State v. Jones" on Justia Law

Randy Collins was tried and convicted for first-degree arson and criminal conspiracy, following a fire that resulted in the death of a 12-year-old boy. The conviction was based, in part, on Collins' statement to law enforcement, which was obtained during an interview where the officers assured Collins that his statements would remain confidential. Collins appealed his conviction, arguing that his statement to law enforcement was involuntary due to the officers' false assurance of confidentiality.The Supreme Court of South Carolina, reviewing the case on certiorari, agreed with Collins. The court held that when law enforcement gave Collins Miranda warnings, but then negated them by falsely advising him that his statements would remain confidential, his statement became involuntary. The court noted that such a false assurance of confidentiality is inherently coercive because it interferes with an individual's ability to make a fully informed decision on whether to engage in an interview.Moreover, the court found that the false assurance of confidentiality was not harmless error. Collins' statement was key evidence linking him to the arson scheme and placing him at the scene of the fire. His situation was distinguishable from cases where the inadmissible evidence is merely cumulative to other properly admitted evidence. Therefore, the court affirmed the court of appeals' decision, albeit with modification, and held that Collins' statement was inadmissible and he was entitled to a new trial. The court also took the opportunity to unequivocally condemn the interviewing technique employed in this case. View "The State v. Collins" on Justia Law

In South Carolina, two hospitals, Walterboro Community Hospital and Trident Medical Center, appealed an Administrative Law Court (ALC) order which approved the certificate of need (CON) for the Medical University Hospital Authority (MUHA). MUHA had applied for a CON to construct a new general hospital in Berkeley County to address capacity issues at its existing hospital in Charleston. The appellant hospitals raised four issues against ALC's decision: 1) the ALC's dismissal of certain errors in the review by the South Carolina Department of Health and Environmental Control (DHEC), 2) a misinterpretation of the State Health Plan by the ALC, 3) the ALC's approval of MUHA's application conditional on the closure of a freestanding emergency department planned by MUHA, and 4) the appeal bond required by South Carolina law is unconstitutional.The Supreme Court of South Carolina affirmed the ALC's decision and held that despite errors in DHEC's review process and decision, the ALC's de novo review rendered these errors harmless. The court also agreed with ALC's interpretation of the State Health Plan and found no issue in the ALC's condition of approval. The court further held that the appeal bond requirement was not unconstitutional, as the appellant hospitals were statutory affected persons and there was a rational basis for different treatment for a party opposing an approved CON and a party appealing the denial of its own CON application. However, the court did instruct that the appeal bond be voided and returned to Trident Medical Center. View "Walterboro Comm Hospital v. SCDHEC" on Justia Law

The Supreme Court of South Carolina affirmed the decision by the court of appeals in the case of Tommy Lee Benton, who was convicted for the murder of Charles Bryant Smith, two counts of first-degree burglary, one count of first-degree arson, and one count of third-degree arson. Benton's first trial was declared a mistrial due to his failure to disclose his alibi, which he intended to support via his great-grandmother's testimony. Benton claimed that his second trial and ensuing convictions were barred by double jeopardy. The court, however, found that the mistrial was declared due to "manifest necessity," hence, there was no double jeopardy violation.Benton also argued against the admissibility of gruesome crime scene photographs and certain text and Facebook messages. The court upheld the trial court's decision, asserting that the photographs provided important context to the testimony and other key evidence. The court noted that while the photographs were disturbing, any error in admitting them was harmless as they did not significantly contribute to the verdict. The court also affirmed the admissibility of the text and social media messages. View "State v. Benton" on Justia Law

In this case, the South Carolina Supreme Court upheld the constitutionality of a state statute that limits reimbursement of reestablishment expenses in condemnation proceedings to $50,000. The appellant, Applied Building Sciences, Inc., an engineering firm, was forced to move its operations when its leased building was condemned for public use by the South Carolina Department of Commerce, Division of Public Railways. The company sought reimbursement for reestablishment expenses exceeding $560,000 but was limited by state statute to $50,000. The company argued that the cap was unconstitutional under the Takings Clauses of the South Carolina and United States Constitutions. The court found that reestablishment expenses are separate from damages awardable as just compensation under both constitutions, thus upholding the constitutionality of the statutory cap. The court affirmed the lower court's granting of summary judgment in favor of the Department of Commerce, Division of Public Railways. View "Applied Building Sciences v. SC Dept of Commerce" on Justia Law

James Heyward was convicted of multiple crimes arising from the armed robbery, brutal beating, and murder of Alice Tollison during the burglary of her home. The South Carolina Supreme Court granted Heyward's petition for a writ of certiorari to address the trial court's refusal to remove Heyward's leg shackles during the striking of the jury, and four evidentiary issues. As to three of the evidentiary issues, the authentication of a fingerprint card, the admission of gruesome autopsy photographs, and the State's use of Heyward's alias, the Supreme Court found the trial court acted within its discretion. As to the other evidentiary issue, a firearms expert's testimony Heyward's pistol was operational at the time of the crimes, the Supreme Court affirmed the court of appeals' ruling that if there was any error in the admission of that testimony it did not prejudice Heyward. As to the leg shackles, the Court found the trial court erred in failing to exercise its discretion in determining whether Heyward should have been required to wear leg shackles in the presence of the jury. However, because the State conclusively proved Heyward's guilt through overwhelming evidence such that no rational conclusion could have been reached other than Heyward is guilty of these crimes, the Court nevertheless affirmed. View "South Carolina v. Heyward" on Justia Law