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South Carolina
Judicial Department
Supreme Court Published Opinions - September 2023

Note: Beginning in June 2012, opinions will be posted as Adobe PDFs. You can download a free copy of Adobe Reader here.

The summary following each opinion is prepared to offer lawyers and the public a general overview of what a particular opinion decides. The summary is not necessarily a full description of the issues discussed in an opinion.


9-6-2023 - Opinions

28177 - State v. Jeroid J. Price

We issued a common-law writ of certiorari to review a "sealed" order of the circuit court reducing the prison sentence of Jeroid John Price and releasing him from prison after he served only nineteen years of his thirty-five-year sentence on his conviction for murder. We previously issued an order unsealing all documents in the case. We now vacate the order for two reasons: (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. We remand the defendant to the custody of the South Carolina Department of Corrections.

9-13-2023 - Opinions

28178 - State v. Robert Lee Miller, III

The Court affirms the decision of the court of appeals, holding that Petitioner's confession to law enforcement was voluntary and, thus, admissible.

9-20-2023 - Opinions

28142 - State v. Stewart Jerome Middleton

At Stewart Jerome Middleton's trial for criminal sexual conduct in the third degree, the State introduced a police detective's testimony that Middleton was evasive in response to her attempts to get Middleton to come in for a voluntary interview. The trial court admitted this testimony over Middleton's relevance objection. We hold the trial court erred in finding the testimony relevant because the State did not establish the required nexus between Middleton's conduct and a consciousness of his guilt. We reverse Middleton's conviction and remand for a new trial.

9-29-2023 - Opinions

28179 - The State v. Corey Jermaine Brown

Corey Brown was convicted of conspiracy to commit grand larceny, armed robbery, and kidnapping. At trial, an alleged co-conspirator testified against Brown after engaging in plea negotiations with the State. The trial court granted Brown's post-trial motion for a new trial because the State failed to disclose its negotiations with the co-conspirator, Shadarron Evans. The court of appeals reversed. This Court reverses the court of appeals and remands for a new trial because the State had a duty under Brady v. Maryland to disclose its negotiations with Evans.

28180 - The Estate of Jane Doe 202 v. City of North Charleston

This Court granted a writ of certiorari to review the court of appeals' decision in Est. of Doe 202 by Doe MM v. City of N. Charleston, 433 S.C. 444, 858 S.E.2d 814 (Ct. App. 2021), holding that the trial court acted within its discretion in not repeating jury instruction on nominal damages in response to jury question. We affirm the court of appeals in result, but also hold that when a trial judge receives an ambiguous question from the jury, the trial court must seek clarification from the jury.