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South Carolina
Judicial Department
Supreme Court Published Opinions - Week of 05/29/2023
5-31-2023 - Opinions

28154 - State v. Guadalupe Guzman Morales
Guadalupe Guzman Morales was convicted in 2017 of criminal sexual conduct with a minor. On appeal, he contends evidence he sexually assaulted the victim's sister should have been excluded under Rule 404(b). He argues the trial court erred in admitting the evidence pursuant to the "common scheme or plan" exception, both under the "substantial similarities" test from State v. Wallace, 384 S.C. 428, 683 S.E.2d 275 (2009), and under the "logical connection" standard we later articulated in State v. Perry, 430 S.C. 24, 842 S.E.2d 654 (2020). The court of appeals agreed as to Perry and reversed. We find both the Wallace and Perry issues are unpreserved for appellate review. To explain our ruling, we explore how the State might have established a "logical connection" in this case had it known it was required to do so. We reverse the court of appeals and reinstate Morales' convictions.
28155 - Amy Garrard v. Charleston County School District
In this defamation action, the Court affirms in result the decision of the court of appeals regarding the entry of summary judgment due to the petitioners' failure to present evidence as to the element of damages.