Justia Constitutional Law Opinion Summaries

Shawn Wyatt appealed his convictions for attempting to furnish contraband to a prisoner and possession with intent to distribute cocaine, cocaine base, and marijuana. He argued the trial court erred by not suppressing two eyewitness identifications. The South Carolina Supreme Court affirmed the trial court's decision not to suppress the primary identification. The Court found, however, the police identification procedure was not unnecessarily suggestive, and thus the trial court should have addressed the suppression question only under the first prong of Neil v. Biggers, 409 U.S. 188 (1972). As to the other identification, the Court found no error and affirmed Wyatt's convictions. View "South Carolina v. Wyatt" on Justia Law

Farid Mangal was convicted of criminal sexual conduct with a minor, lewd act upon a child, and incest. After his convictions were affirmed, Mangal filed an action for post-conviction relief (PCR), arguing his trial counsel was ineffective for not objecting to improper bolstering testimony. The PCR court refused to rule on the improper bolstering issue because the court found Mangal did not raise it in his PCR application or at the PCR hearing. The court of appeals reversed, finding the improper bolstering issue was raised to the PCR court. The court of appeals then proceeded to grant PCR on the merits of the issue. In reversing the court of appeals, the South Carolina Supreme Court determined the court of appeals relied on several additional portions of the testimony at issue here that was not revealed to the PCR court at any point during the PCR hearing. With regard to the PCR court's exercise of discretion in refusing to address the improper bolstering issue, Mangal filed a Rule 59(e) motion asking the PCR court to consider the claim. The PCR court denied the motion, finding "no testimonial evidence . . . was presented in support of these allegations." The South Carolina Supreme Court agreed with the PCR court and reinstated its order. View "Mangal v. South Carolina" on Justia Law

Petitioners South Carolina Public Interest Foundation and Edward Sloan, individually and on behalf of all others similarly situated, filed a declaratory judgment action against Respondents the South Carolina Department of Transportation ("SCDOT") and John Walsh, Deputy Secretary of Transportation for Engineering of SCDOT. Petitioners sought a declaration that SCDOT's inspection of three privately owned bridges violated sections 5 and 11 of article X of the South Carolina Constitution, which Petitioners asserted prohibit the expenditure of public funds for a private purpose. The trial court granted Respondents' motion for summary judgment, finding: Petitioners lacked standing; the controversy was moot and did not fall under any of the exceptions to the mootness doctrine; and Respondents' actions were not ultra vires or unconstitutional. The Court of Appeals affirmed. The South Carolina Supreme Court concluded, after review: (1) Petitioners established public importance standing; (2) the Court of Appeals erred in concluding this matter was not justiciable because Respondents admitted their conduct was wrongful; (3) Respondents' inspection of the privately owned bridges was unconstitutional because it contravened the constitutional requirement that the expenditure of public funds serve a public purpose. The Court concluded Respondents' conduct was unconstitutional and ultra vires, and reversed the Court of Appeals' judgment. View "South Carolina Public Interest Foundation v. SCDOT" on Justia Law

Renwick Mose appealed the dismissal of his application for post-conviction relief. The application was denied for being three days past the statute of limitations period ended, but Mose contended he delivered the application to prison authorities within the statutory period. Mose sought reversal of the PCR judge's ruling so that he could receive a hearing on the merits of his application. After review, the South Carolina Supreme Court concluded the PCR judge erred in summarily dismissing Mose's PCR application as untimely, reversed and remanded for a hearing on the merits. View "Mose v. South Carolina" on Justia Law

The issue in this case arose from classifications contained in South Carolina's domestic violence statutes. Specifically, the classifications provided that only "Household member[s]," defined as, inter alia, a "male and female who are cohabiting or formerly have cohabited," are protected under the statutes. Petitioner challenged these classifications, arguing they unconstitutionally exclude unmarried, cohabiting or formerly cohabiting, same-sex couples from the protection of the domestic violence statutes. Petitioner asked the South Carolina Supreme Court to declare that the subsections which exclude same-sex couples, S.C. Code Ann. 16-25-10(3)(d) (effective June 4, 2015), of the Domestic Violence Reform Act, and S.C. Code Ann. 20-4-20(b)(iv) (effective June 4, 2015), of the Protection from Criminal Domestic Violence Act (collectively "the Acts"), violated the Due Process and Equal Protection Clauses of the Fourteenth Amendment to the United States Constitution. The Court agreed the definitional subsections at issue offend the Equal Protection Clause, and, therefore, struck the subsection from each Act. View "Doe v. South Carolina" on Justia Law

Farid Mangal was convicted of criminal sexual conduct with a minor, lewd act upon a child, and incest. After his convictions were affirmed, Mangal filed this action for post-conviction relief (PCR), arguing trial counsel was ineffective for not objecting to improper bolstering testimony. The PCR court refused to rule on the improper bolstering issue because the court found Mangal did not raise it in his PCR application or at the PCR hearing. The court of appeals reversed, finding the improper bolstering issue was raised to the PCR court. The court of appeals then proceeded to grant PCR on the merits of the issue before it was considered by the PCR court. Finding the appellate court erred in its conclusion, the South Carolina Supreme Court reversed the court of appeals and reinstated the PCR court's order. View "Mangal v. South Carolina" on Justia Law

The Surface Water Withdrawal, Permitting, Use, and Reporting Act regulated surface water withdrawals in South Carolina. Surface water is defined as "all water that is wholly or partially within the State . . . or within its jurisdiction, which is open to the atmosphere and subject to surface runoff, including, but not limited to, lakes, streams, ponds, rivers, creeks, runs, springs, and reservoirs . . . ." Agricultural users are treated differently under the Act. Plaintiffs jointly filed this action against DHEC in Barnwell County, challenging the Act's registration system for agricultural users, contending, amongst other things, that the Act’s provisions were an unconstitutional taking, a violation of due process, and a violation of the public trust doctrine. The circuit court granted summary judgment against the plaintiffs on the grounds the case did not present a justiciable controversy, both because the plaintiffs lacked standing and the dispute was not ripe for judicial determination. Finding no reversible error with that holding, the South Carolina Supreme Court affirmed. View "Jowers v. SCDHEC" on Justia Law

Petitioner and his “enlisted cohorts” went to, in petitioner’s estimation, peacefully retrieve his forty-seven-inch plasma-screen television from Kevin Bowens (Victim). Victim was shot and killed on his property by one of Petitioner's accomplices during the confrontation. Petitioner was convicted of murder. The State contended the evidence demonstrated that Petitioner intended to retrieve his television by any means necessary, including the use of force. According to the State, Victim's death was therefore a natural and foreseeable consequence of Petitioner's plan to retrieve his television and, under the theory of accomplice liability that says the “hand of one is the hand of all,” Petitioner was guilty of murder. Petitioner countered he only wanted to peacefully reclaim his television, he had no idea his accomplice was armed, and he actually tried to be a calming influence when the situation became tense. The court of appeals affirmed, holding the trial court properly denied Petitioner's motion for a directed verdict. Finding no reversible error in that judgment, the South Carolina Supreme Court affirmed. View "South Carolina v. Harry" on Justia Law

Appellant's unrelenting inappropriate conduct in the South Carolina courts necessitated that certain restrictions be placed upon Appellant's pro se access to the courts to curb her abuse of the judicial process. In a direct appeal, Appellant Marie-Therese Assa'ad-Faltas appealed her simple assault conviction and sentence, arguing her right to self-representation was violated and that she was entitled to a new trial in which she represents herself. For many years, Appellant has engaged in a pattern of frivolous filings and inappropriate conduct towards the courts, court officers, and court employees of this State. Appellant's abuse of the justice system even reached the United States Supreme Court. In light of this and after carefully considering the facts of this case, for the reasons that follow, the South Carolina Supreme Court affirmed Appellant's conviction and sentence. View "City of Columbia v. Assa'ad-Faltas" on Justia Law

A jury convicted Ricky Lee Blackwell of kidnapping and killing eight-year-old Heather Brooke Center ("Brooke"), the daughter of his ex-wife's boyfriend, and recommended a sentence of death. After twenty-six years of marriage, Blackwell's wife, Angela, entered into an adulterous relationship with Bobby Center. Blackwell was devastated when Angela left him. Following the breakup, Blackwell attempted suicide, suffered financial problems, and was forced to turn to his parents for support. A confrontation with Angela ended with Blackwell grabbed Center’s eight-year-old daughter and held a gun to her head. Blackwell ignored Angela's pleas for him to release the child. Instead, Blackwell stated that Angela had "pushed this too far," that she "did this," and that she could let him know "what Bobby thinks of this." Blackwell then fatally shot Brooke. Following the shooting, Blackwell fled into the woods behind his daughter's home. When law enforcement surrounded him, Blackwell shot himself in the stomach and was taken to the hospital. While being transported to the hospital and waiting for treatment, Blackwell gave inculpatory statements to the law enforcement officers who questioned him. Blackwell appealed, contending the trial court erred in: (1) finding him eligible for the death penalty despite evidence of mental retardation; (2) failing to disqualify a juror for cause; (3) denying his "Batson" challenge; (4) prohibiting him from cross-examining a State witness using privileged statements the witness made to a mental health counselor and declining to accept the proffer of the mental health records as an exhibit; (5) declining to admit notes of two hospital chaplains as evidence that he was remorseful; and (6) failing to correctly instruct the jury regarding a finding of mental retardation during the penalty phase of the trial. The South Carolina Supreme Court affirmed Blackwell's convictions and sentence. View "South Carolina v. Blackwell" on Justia Law