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Brackenbrook North Charleston, LP v. County of Charleston

Citations: 366 S.C. 503; 623 S.E.2d 91; 2005 S.C. LEXIS 356Docket: No. 26070

Court: Supreme Court of South Carolina; November 27, 2005; South Carolina; State Supreme Court

Narrative Opinion Summary

The case involves appellants challenging a circuit court's ruling regarding jurisdiction over a post-remittitur request for attorneys' fees and a motion for compliance with a Supreme Court mandate. Initially, the circuit court dismissed both requests, asserting a lack of jurisdiction. The appellants argued that the court did have jurisdiction over the attorneys' fees motion and appealed the decision. The appellate court agreed that the circuit court had jurisdiction to consider the attorneys' fees request, as jurisdiction is conferred upon the receipt of the remittitur. However, it affirmed the lower court's decision due to the absence of any demonstrated prejudice against the appellants, who were not entitled to fees under S.C.Code Ann. 15-77-310, as the respondents had acted with substantial justification. In a related case, the Supreme Court had previously reversed and remanded with instructions to dismiss without prejudice, affecting the appellants' refund pursuit. The circuit court had also correctly determined it lacked jurisdiction over compliance matters, as these were directed towards non-parties. The appellants' claim for fees under the 'common fund' theory was withdrawn during oral arguments. Consequently, the appellate court upheld the circuit court's orders, maintaining that the appellants were not entitled to additional relief.

Legal Issues Addressed

Eligibility for Attorneys' Fees under S.C.Code Ann. 15-77-310

Application: Appellants timely filed their request for attorneys' fees within thirty days following the filing of the remittitur, but their claim was negated as Respondents successfully argued the circuit court was not the appropriate forum for the tax refund request.

Reasoning: Appellants timely requested attorneys' fees within thirty days following the circuit court's filing of the Brackenbrook I remittitur, as permitted under S.C.Code Ann. 15-77-310.

Jurisdiction of Circuit Court Post-Remittitur

Application: The circuit court initially erred in concluding it lacked jurisdiction to consider the appellants' request for attorneys' fees post-remittitur, as jurisdiction is conferred upon the circuit court upon receipt of the remittitur.

Reasoning: The circuit court mistakenly concluded it lacked jurisdiction to consider this request; jurisdiction is conferred upon the circuit court upon receipt of the remittitur, as established in case law.

Mandate Enforcement and Jurisdiction

Application: The circuit court correctly declined to consider the appellants' compliance motion, as the appellate court's mandate did not fall under its jurisdiction regarding the appellants.

Reasoning: The circuit court appropriately declined to consider Appellants’ Motion to Shorten Time and Determine Compliance.

Prejudice Requirement for Reversal of Error

Application: The court upheld the circuit court's ruling due to the appellants' failure to demonstrate prejudice from the jurisdictional error regarding attorneys' fees.

Reasoning: However, Appellants failed to demonstrate prejudice from this error, which is necessary for reversal.