Eugene Satterwhite Blease

The case involved the appeal of Clarence Floyd from his conviction and death sentence for rape in Lexington County, South Carolina, following an alleged incident on August 5, 1933. The defendant, represented by appointed counsel, was tried after arraignment, and the appeal raised exceptions primarily challenging the sufficiency of the evidence, the plausibility of the victim's account, and the state's handling of an alibi defense. The court affirmed the judgment, reasoning that the trial record showed no errors in the admission of evidence, jury instructions, or constitutional violations, that the jury had properly weighed the facts and witness credibility, and that claims regarding after-discovered evidence or mercy were outside the court's appellate role limited to correcting legal errors. The court emphasized the fairness of the proceedings and the binding nature of the jury's verdict on factual disputes.

criminal law

In Jackson v. City of Columbia, the case concerned the liability of municipal corporations in South Carolina for damages to persons and property arising from defects in streets, sidewalks, and bridges. The concurring opinion examines the 1892 statutes on this subject, noting that Dunn v. Town of Barnwell interpreted the narrower Act No. 40 while overlooking the broader provisions in Act No. 46, and that a 1901 Act added further liability language for larger cities that was never incorporated into the state Codes. The court concludes that the statutory law remains as construed in Dunn and subsequent cases such as Reeves v. City of Hasley, and therefore follows that precedent without giving effect to the uncodified 1901 proviso. The opinion suggests any expansion of liability is a matter for the legislature.

torts & liability

The case involved a suit by the administrator of a deceased insured's estate against Metropolitan Life Insurance Company for breach of a life insurance contract, accompanied by fraudulent acts, seeking both actual damages equal to the policy amount and punitive damages. The policy had been issued based on the applicant's representations of good health and no recent medical care, but the insured died of tuberculosis shortly after issuance, leading the company to deny the claim under policy conditions allowing voidance for preexisting conditions not disclosed. The trial court awarded both actual and punitive damages, but on appeal the South Carolina Supreme Court affirmed the actual damages verdict, finding some evidence of possible waiver by the company's agent, while reversing the punitive damages award. The court held that punitive damages require proof of a fraudulent act accompanying the breach, which was absent here as the company's denial was based on information in the proofs of death without evidence of fraud by its agents. The decision emphasized that a mere breach of contract, even if willful, does not support punitive damages without accompanying fraud.

business & regulatorytorts & liability

This case involved a wrongful death action brought by the administratrix of Harry B. Price against his employer, American Agricultural Chemical Co., and its superintendent, alleging negligence caused Price's death while he worked as a chamber walker operating machinery at the plant. The trial court granted a nonsuit to both defendants, but the Supreme Court reversed, holding that the evidence presented by the plaintiff raised triable issues of negligence. The court reasoned that the superintendent's act of starting the pumps without first ascertaining the employee's location could constitute a breach of the employer's nondelegable duty to supervise machinery safely and protect employees from known dangers. It further concluded that whether the superintendent's conduct qualified as that of a fellow servant was a factual question for the jury rather than a basis for nonsuit. The case was remanded for a new trial.

torts & liabilitylabor & employment

The case concerned a claim on an automobile insurance policy issued by the defendant to the plaintiff, under which the insurer sought to avoid liability because the vehicle was being driven by the plaintiff's 15-year-old son at the time of the accident, contrary to a policy exclusion for operation by anyone under age 16. The trial court overruled the insurer's demurrer and motions and entered judgment for the plaintiff. On appeal, the South Carolina Supreme Court affirmed, ruling that an insurer relying on such an exclusion must demonstrate a causal connection between the underage driving and the collision; the court found no logical basis for distinguishing between exclusions tied to unlawful acts and those tied to conditions, and it applied its prior decision in Reynolds v. Life & Casualty Insurance Co. that required proof of causation under similar policy language.

business & regulatoryproperty

This case concerns preferences in the distribution of assets from insolvent banks under South Carolina law. The opinion discusses prior decisions including Ex parte Sanders, Ex parte Town of Darlington, and In re Loan Savings Bank, noting ongoing confusion caused by efforts to achieve equitable results rather than applying established legal principles. The court concludes that it must clarify the governing rules so the law is plain and consistent, and concurs in the result on the understanding that the principles stated in this opinion will be followed going forward.

business & regulatory