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Forest Dunes Associates v. Club Carib, Inc.

Citations: 301 S.C. 87; 390 S.E.2d 368; 1990 S.C. App. LEXIS 22Docket: 1460

Court: Court of Appeals of South Carolina; February 19, 1990; South Carolina; State Appellate Court

Narrative Opinion Summary

In this case, respondents sought to evict Club Carib, Inc. from the Caribbean Cafe Restaurant in Myrtle Beach, South Carolina. The appellant counterclaimed for a declaratory judgment regarding a valid lease and damages for breach of quiet enjoyment. A special referee ruled in favor of the respondents, ordering eviction, awarding back rent, and dismissing the appellant's counterclaims. The appellant challenged the referee’s order with eleven exceptions, though five were abandoned due to lack of argument in their brief. The remaining exceptions contested the referee's decisions on estoppel, lease validity, eviction, tenant classification, and breach of quiet enjoyment. The court dismissed the appeal, finding the exceptions non-compliant with Supreme Court Rule 4.6 due to their vague and broad nature. After reviewing the record, the court found no error in the referee’s findings, affirming the decision. Judges Sanders and Goolsby concurred with the ruling, resulting in the appellant's eviction and dismissal of their claims.

Legal Issues Addressed

Breach of Quiet Enjoyment

Application: The appellant's claim of a breach of the quiet enjoyment warranty was dismissed for lack of supporting evidence.

Reasoning: The remaining six exceptions included claims that the referee erred in:... (5) not acknowledging a breach of the quiet enjoyment warranty; and (6) failing to award damages for that breach.

Declaratory Judgment on Lease Validity

Application: The appellant's counterclaim for a declaratory judgment asserting a valid lease was dismissed by the referee.

Reasoning: Appellant counterclaimed for a declaratory judgment asserting a valid lease and damages for breach of quiet enjoyment.

Estoppel in Lease Disputes

Application: The appellant's claim that respondents were estopped from denying the lease's validity was not upheld by the court.

Reasoning: Appellant raised eleven exceptions to the referee’s order but abandoned five... The remaining six exceptions included claims that the referee erred in: (1) failing to find respondents estopped from denying the lease's validity;

Eviction Proceedings and Tenant Rights

Application: The court upheld the referee's decision to order eviction and award back rent, dismissing the appellant's counterclaims.

Reasoning: A special referee ruled in favor of respondents, ordering eviction, awarding back rent, and dismissing the counterclaims.

Exceptions to Judicial Orders and Compliance with Procedural Rules

Application: The court dismissed the appeal due to the appellant's failure to comply with Supreme Court Rule 4.6, citing vague and overly broad exceptions.

Reasoning: The court found that the exceptions did not comply with Supreme Court Rule 4.6, which requires each exception to contain a concise statement of law or fact and a complete assignment of error.

Tenant-at-Will Classification

Application: The referee's classification of the appellant as a tenant-at-will was contested but ultimately upheld.

Reasoning: The remaining six exceptions included claims that the referee erred in:... (4) classifying appellant as a tenant-at-will;