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Blanks v. Rawson

Citations: 370 S.E.2d 890; 296 S.C. 110; 1988 S.C. App. LEXIS 108

Court: Court of Appeals of South Carolina; July 11, 1988; South Carolina; State Appellate Court

Narrative Opinion Summary

The South Carolina Court of Appeals reviewed a dispute between neighbors over alleged violations of neighborhood restrictions in the Indian Fork subdivision. The Blanks claimed that Rawson's constructions, including a dog pen, basketball goal, and a ten-foot privacy fence, violated setback limits and constituted nuisances due to noise, odor, and obstruction of views. The trial court ordered modifications to Rawson's structures, but Rawson appealed. The appellate court found that Rawson had obtained permission from the Indian Fork Development Company to construct his facilities, thus not violating setback restrictions. While the trial court identified nuisances under Paragraph Eight of the Declaration of Restrictions, the appellate court found insufficient evidence to substantiate such claims, especially regarding the basketball goal. The court upheld the trial judge’s findings about the dog pen’s maintenance as a nuisance due to conflicting testimonies. Regarding the fence, although it obstructed the Blanks' view, the court noted that the Declaration did not protect views, and South Carolina law does not recognize a prescriptive easement for views. Consequently, the court affirmed the trial court’s decision in part and reversed it in part, maintaining privacy rights for both parties.

Legal Issues Addressed

Equitable Relief and Injunctions

Application: The court acknowledged the equitable nature of the injunction sought by the Blanks, considering the evidence's preponderance and the trial judge's position to assess witness credibility.

Reasoning: The court noted that an injunction is an equitable action, and appellate review will consider the evidence's preponderance.

Nuisance Under Neighborhood Restrictions

Application: The court assessed whether the basketball goal and dog pen created nuisances under Paragraph Eight of the Declaration of Restrictions, ultimately finding that the nuisances were not substantiated.

Reasoning: The trial court found that the proximity of the basketball goal and dog pen created nuisances, with the noise of the basketball and the sight and smell of the dog pen being significant factors.

Prescriptive Easement for Views

Application: The court concluded that South Carolina law does not recognize a prescriptive easement for views, thus affirming Rawson's right to maintain the fence despite obstructing the Blanks’ view.

Reasoning: South Carolina law does not recognize a prescriptive easement for views.

Setback Requirements and Developer Permissions

Application: The court found that Rawson did not violate setback limits as he had obtained permission from the Indian Fork Development Company to place the dog pen, basketball goal, and fence.

Reasoning: Rawson had obtained permission from the Indian Fork Development Company to vary setback requirements for his constructions, including the dog pen and basketball goal, which were positioned near the property line.