The case involved a worker injured by allegedly defective textile machinery who sued the manufacturer solely under a strict liability theory and obtained a jury verdict that included both actual and punitive damages. The South Carolina Supreme Court, answering a certified question from federal district court, held that punitive damages are not recoverable in an action based solely on strict liability. The court reasoned that the state's 1974 strict liability statute, which incorporated Restatement (Second) of Torts §402A almost verbatim, creates liability only "for physical harm caused" and therefore authorizes only actual compensatory damages; punitive damages, being a separate remedy for punishment and deterrence rather than compensation, were not provided for by the legislature. Because the cause of action was statutorily created, the court concluded that it lacked authority to expand the available remedies beyond the plain terms of the statute.
This case involves an action on a guaranty agreement where the bank sought to recover a deficiency after a default. The South Carolina Supreme Court affirmed the Court of Appeals' decision as modified, holding that the trial court improperly limited the guarantors' liability but that the appellate court could not determine the exact deficiency amount based solely on proffered testimony without a hearing on remand. The court also ruled that the bankruptcy filings by two petitioners did not automatically stay the proceedings, as the action was not against the debtors in its current posture and the outcome would not diminish their estates.
In this mortgage foreclosure action, Sunrise Savings & Loan Association sought to foreclose on mortgages securing a $2.8 million note from Mariner’s Cay Development Corporation and to hold Knight liable for any deficiency as guarantor under an Unconditional Continuing Guarantee. The court affirmed the judgment against Knight, ruling that the guarantee was not a negotiable instrument under the UCC and thus Knight could not raise a defense of unjustifiable impairment of collateral. The court reversed the $125,000 attorney’s fees award on the first cause of action, however, because the record contained no evidence supporting the reasonableness of the fees or allocating them among the five causes of action, and it remanded for a redetermination based on proper evidence.
This case involves a dispute over ownership of two tracts of land between sisters claiming title through a chain of inheritance from Lemon Mack and the Fobbs family claiming title through adverse possession based on decades of farming, tax payments, and improvements. The master-in-equity ruled that the sisters held title to both tracts and that the Fobbs had not established adverse possession. The court affirmed the title determination for the Lemon Mack tract, finding sufficient evidence to support the sisters' chain of title. It reversed on adverse possession, however, because the master applied an erroneous legal standard for hostility in a non-boundary dispute and improperly admitted hearsay and testimony barred by the Dead Man's Statute, and remanded for redetermination of that issue.
This case concerned a divorced wife's efforts to enforce support payments by having a family court attach and garnish her ex-husband's state retirement account after he quit his job and stopped paying. The family court ordered the state retirement system to disburse funds for arrearages, costs, and ongoing monthly support, but the South Carolina Supreme Court reversed. The court held that while a later statute permitted garnishment of retirement income in support cases, it applied only when actual payments were being made to the retiree, not when funds remained untouched in the system. The state system was found to have standing to appeal the order requiring it to make payments.
This case involved an employee seeking severance benefits, including a year-end bonus, notice pay, and payments under a non-competition clause, after being terminated for cause by his employer. The court affirmed the denial of these benefits, holding that the employment contract did not clearly alter the general rule that termination for cause extinguishes rights to such benefits. However, the court modified the order to award the employee payments under the non-competition clause for the period between termination and the company's notice that it would not enforce the clause, reasoning that the employer could choose to abandon the non-compete upon a for-cause termination due to the employee's breach of loyalty.