Island Preservation v. Fenwick Properties

CourtCourt of Appeals of South Carolina
DecidedJuly 19, 2010
Docket2010-UP-369
StatusUnpublished

This text of Island Preservation v. Fenwick Properties (Island Preservation v. Fenwick Properties) is published on Counsel Stack Legal Research, covering Court of Appeals of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Island Preservation v. Fenwick Properties, (S.C. Ct. App. 2010).

Opinion

THIS OPINION HAS NO PRECEDENTIAL VALUE.  IT SHOULD NOT BE CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.

THE STATE OF SOUTH CAROLINA
In The Court of Appeals

Island Preservation Company, LP and Thomas Dewey Wise, Respondents,

v.

State of South Carolina and the South Carolina Department of Natural Resources, and Fenwick Properties, LLC, Defendants,

Of Whom Fenwick Properties, LLC is Appellant.

Appeal From Colleton County
Carmen T. Mullen, Circuit Court Judge


Unpublished Opinion No. 2010-UP-369
Heard April 13, 2010 – Filed July 19, 2010


DISMISSED


Richard L. Tapp, Jr., and Stephen P. Groves, Sr., of Charleston, for Appellant.

David K. Haller, of Charleston, for Respondents.

PER CURIAM: Fenwick Properties appeals the trial court's order granting partial summary judgment to Island Preservation Company and Thomas Dewey Wise (collectively Island Preservation), in which the court upheld a 1984 order declaring Island Preservation's predecessor-in-title fee simple owner of marshland (Marsh Property) due to a King's Grant.  We find Fenwick Properties is not a party aggrieved by this order and dismiss. 

FACTS/PROCEDURAL HISTORY

In the fall of 1983, Dewey Wise contracted to purchase several hundred acres of land on South Fenwick Island.  For tax purposes, he asked his law partner at the time, W. Gregory Pearce, to act as his agent in the transaction.  At the closing on the property, title was placed in Pearce's name, even though Wise provided all of the funds for the purchase price.  A declaratory judgment action was brought in Pearce's name against the State of South Carolina requesting a declaration Pearce was the owner in fee simple to the mean low water mark by virtue of a King's Grant.  Before the court issued its ruling in the declaratory judgment action, Pearce conveyed the property to Wise.  Neither Pearce nor Wise moved to amend the complaint in the action to substitute Wise as a party.  In October of 1984, the court issued an order ruling the property line extended to the low water mark.  This order was not appealed.  Wise subsequently transferred the property to Island Preservation Company, of which he is the general partner.  When questions arose concerning the King's Grant in 2005, Pearce executed a quit claim deed for the Marsh Property within the King's Grant. 

In April of 2006, Island Preservation brought the present declaratory judgment action against the State seeking a declaration the October 1984 order was valid.  In its second amended complaint, it named as Defendants both the State and the South Carolina Department of Natural Resources (DNR), which by way of a 2005 deed from the Nature Conservatory may have a competing claim to a portion of the Marsh Property.  In addition to requesting a declaration concerning the validity of the 1984 order, it asked for a declaration that its title was superior to any competing claim.  In the alternative, it requested the court find it possessed fee simple title to the tidelands between the high water mark and low water mark as it can trace its title to King George II of England.  In their answer, the State and DNR asserted the 1984 order was not valid because the named plaintiff, Gregory Pearce, had conveyed the property prior to the issuance of the order.  They also asked for a declaration DNR's 2005 deed prevailed over any claim Island Preservation had to the overlapping property and for an adjudication of the boundaries between DNR and Island Preservation's properties. 

Fenwick Properties moved to intervene in the proceedings, claiming an interest due to its ownership of property on South Fenwick Island, possession of an easement over Island Preservation's property, and being the holder of a dock permit over the disputed marsh.  The trial court granted the motion to intervene.  It subsequently granted Island Preservation's motion for partial summary judgment.  It held Pearce was a real party in interest in the 1984 litigation, and thus, the 1984 order was valid.  The court stated the remaining issues between the parties would be litigated later. 

All of the defendants moved for reconsideration of the order.  In the substituted order, the court again found the 1984 order to be valid.  It noted:  "Fenwick Properties, which seeks to have an easement at the location interpreted, has no claim to fee simple title to the tidelands.  The arguments offered by Fenwick Properties concern the validity of the grant; it has not questioned the validity of the 1984 order."  It reiterated the remaining issues not covered in the order granting summary judgment could still be litigated, "specifically the State's claims relating to its 2005 deed to the marshes of Pine Island and the claims of Fenwick Properties."  This appeal followed.    

LAW/ANALYSIS

Island Preservation argues Fenwick Properties does not have the right to appeal the trial court's order as it is not a party aggrieved by the order.  We agree. 

The South Carolina Appellate Court Rules limit the ability to appeal to “[o]nly a party aggrieved by an order, judgment . . . or decision. . . .”  Rule 201(b), SCACR.  As used by this rule, the word "aggrieved" means "a substantial grievance, a denial of some personal or property right, or the imposition on a party of a burden or obligation.”  Powell ex rel. Kelley v. Bank of Am., 379 S.C. 437, 447, 665 S.E.2d 237, 243 (Ct. App. 2008).  “A party is aggrieved by a judgment or decree when it operates on his or her rights of property or bears directly on his or her interest.” Id.  "There is no material distinction in general standing principles juxtaposed to the ability of an 'aggrieved party' to appeal pursuant to Rule 201(b)."  Id. at 447, 665 S.E.2d at 242. 

Standing concerns whether a party has “sufficient interest in the outcome of the litigation to warrant consideration of that party's position by a court.  Powell, 379 S.C. at 444, 665 S.E.2d 237 at 241.  Generally, to have standing, a party must have a personal stake in the subject matter of the litigation.  Michael P. v. Greenville Dep't of Soc. Servs., 385 S.C. 407, 415-16, 684 S.E.2d 211, 215 (Ct. App. 2009).

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Related

I'On, L.L.C. v. Town of Mt. Pleasant
526 S.E.2d 716 (Supreme Court of South Carolina, 2000)
Powell Ex Rel. Kelley v. Bank of Am.
665 S.E.2d 237 (Court of Appeals of South Carolina, 2008)
Lowcountry Open Land Trust v. State
552 S.E.2d 778 (Court of Appeals of South Carolina, 2001)
Ex Parte Government Employee's Ins. Co.
644 S.E.2d 699 (Supreme Court of South Carolina, 2007)
Michael P. v. Greenville County Department of Social Services
684 S.E.2d 211 (Court of Appeals of South Carolina, 2009)

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Bluebook (online)
Island Preservation v. Fenwick Properties, Counsel Stack Legal Research, https://law.counselstack.com/opinion/island-preservation-v-fenwick-properties-scctapp-2010.