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Insurers Take Heed: South Carolina Law Does Not Require Apportionment of Punitive Damages

In a significant but not entirely novel ruling, the South Carolina Supreme Court recently held that South Carolina law does not require the pro rata apportionment of punitive damages between damages sustained for bodily...more

In Case You Were Wondering About Amount in Controversy...

Probably every practitioner has faced the situation. The goal is to remove the case to the United States District Court. There is complete diversity, but the amount in controversy is ambiguous; plaintiff seeks actual and...more

Fourth Circuit Offers a Quick Look at Defamation in South Carolina

In a slander action before the United States District Court on diversity jurisdiction, the jury returned a verdict awarding Plaintiff compensatory and punitive damages. The Defendant’s motion for judgment as a matter of law...more

Continued Support for Forum Selection Clauses

Little more than a month ago, we looked at the United States District Court’s application of a recent Fourth Circuit opinion that relied, in turn, on a United States Supreme Court opinion addressing venue challenges in light...more

A Pleading Primer

The United States District Court recently provided a pleading primer on a number of causes of action. Hall v. Storm Team Construction, Inc, et al. 2018 WL 2461991 (June 1, 2018). Plaintiff was hired as a project manager by...more

South Carolina Supreme Court: Insurer May Sue Defense Counsel in Malpractice

Last week, the South Carolina Supreme Court handed down a monumental opinion; one which, in the words of appellant’s counsel, changes 200 years of common law....more

The United States District Court Takes Another Look at South Carolina's Statute of Repose

Several months ago, we addressed the United States District Court’s helpful analysis of selected portions of South Carolina’s statute of repose. That case is back before the court, and there is additional clarification as to...more

Reconsideration of Interlocutory Orders - The breadth and limitation of Federal Rule of Civil Procedure 54(b)

A district court may revise “any order or other decision…that adjudicates fewer than all the claims or the rights and liabilities of fewer than all the parties…at any time before the entry of a judgment adjudicating all the...more

Can a Third Party Seek a Declaration of an Insurer's Duties Under Its Policy?

“Be careful what you ask for in your declaratory judgment action” could have been an appropriate subtitle....more

Is Your Forum Selection Clause Mandatory or Permissive: How to know the difference and why you should.

Drafting an agreement that includes a forum selection clause? Preparing to litigate an agreement that includes a forum selection clause and wondering how to argue? The United States District Court, relying on a recent...more

Does South Carolina Recognize an Evidentiary Privilege for Trade Secrets?

The Fourth Circuit recently certified this question to the South Carolina Supreme Court in Theodore G. Hartsock, Jr., as Personal Representative of the Estate of Sarah Mills Hartsock v. Goodyear Dunlop Tires North America,...more

Insurer's Successful Declaratory Judgment Action Provides a Refresher on Insurable Interest

It is a basic rule of law - one cannot insure, for his own benefit, the property of another. Recovery under an insurance policy requires proof of an insurable interest in the subject property at the time the policy is...more

South Carolina’s Support of Arbitration Continues to Grow

Previously, in order to have an enforceable arbitration agreement in South Carolina, the arbitration language had to appear on the pages of the contract in bold, UPPER CASE and underlined print. Now, arbitration agreements...more

Mediation, Confidentiality and Set-Off - Take Two

The title to this article could have been Mediation – Where the Confidentially Ends and Set-Off Begins, Revisited. However, the wonderful and talented people who edit my edits told me that title is too long. Nonetheless, that...more

Federal Declaratory Judgment Act - What is Required for Standing?

To establish federal jurisdiction in a declaratory judgment action, two conditions must be satisfied. First, is the constitutional inquiry - the case must be a ‘case or controversy’ pursuant to Article III of the US...more

When Does the Time to Appeal Begin? Check your email.

Rule 203(b)(1), South Carolina Appellate Court Rules (SCACR), requires notice of appeal be served within thirty days after receiving written notice of entry of an order or judgment. While the notice of appeal must be served...more

Amount in Controversy for Diversity Jurisdiction: How to Determine When Damages Are Not Clearly Stated

Diversity jurisdiction exists when there is complete diversity of citizenship between the parties and the amount in controversy exceeds $75,000. Generally, the amount in controversy articulated in Plaintiff’s complaint is...more

The Evolution of Ripeness Affords Additional Opportunities for Declaratory Judgment Actions

In Colony Insurance Company v. Hucks Pool Company, Inc., et al. (February 15, 2018), based only upon a demand letter to Hucks from a claimant, Colony filed a declaratory judgment action that sought a determination whether it...more

Not Every Refusal to Provide Coverage Equals Bad Faith

A complicated and interesting factual history, along with a number of actions, including an earlier one for declaratory judgment, resulted in a thoughtful and reasoned opinion of the United States District Court for South...more

Statutory Construction is Powerful

The Court Interprets “Due Date” Under a Premium Service Agreement - The tools of statutory construction are powerful. In interpreting statutory language, words are generally given their common and ordinary meaning. The...more

South Carolina's Statute of Repose - A look by the United States District Court

S.C Code §15-3-640, provides, in pertinent part: No actions to recover damages based upon or arising out of the defective or unsafe condition of an improvement to real property may be brought more than eight years after...more

Who Is Insured, What Is Insured and Why Makes a Difference

What do the Moody Blues and an insurance policy have in common? It boils down to this: Say what you mean and mean what you say. The District Court of South Carolina recently reminded us of the importance of the terms of...more

An Insurance Contract is Still a Contract - And How That Impacts Voluntary PIP Coverage

In two recent opinions, the SC Court of Appeals reminded readers that parties are free to contract as they see fit, as long as the contract provisions at issue are not contrary to public policy or a statutory prohibition. It...more

Application of the Twenty-Year Statute of Limitations S.C.Code Ann. §15-3-520(a) - SC Mortgage Not Required

Most breach of contract claims in S.C. are governed by a three-year statute of limitations. S.C. Code Ann. § 15-3-530(1). A specific exception, however, is found in S.C. Code Ann §15-3-520(a) that provides for a twenty-year...more

Bad Faith – Another Angle

In August 2011, Jeffrey Vanderhall was riding his bicycle when he was hit by a car and seriously injured. It is now six years, three courts and two bad faith attempts later... To describe the procedural history of this...more

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