Rene Wells v. David Shealy

CourtCourt of Appeals of South Carolina
DecidedJanuary 14, 2026
Docket2022-001602
StatusUnpublished

This text of Rene Wells v. David Shealy (Rene Wells v. David Shealy) 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
Rene Wells v. David Shealy, (S.C. Ct. App. 2026).

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

Rene S. Wells and Wilson Shealy, Jr. as Co-Personal Representatives of Wilson Shealy, Sr., Respondent,

v.

David Shealy, Appellant,

AND

Renee Shealy Wells, Wilson Shealy, Jr., and Mimi Shealy, Respondents.

Appellate Case No. 2022-001602

Appeal From Lexington County Walton J. McLeod, IV, Circuit Court Judge

Unpublished Opinion No. 2026-UP-008 Submitted October 1, 2025 – Filed January 14, 2026

AFFIRMED IN PART, REVERSED IN PART, AND REMANDED Tobias Gavin Ward, Jr., and James Derrick Jackson, both of Tobias G. Ward, Jr., PA, of Columbia, for Appellant.

Richard R. Gleissner, of Gleissner Law Firm, LLC, of Columbia, for Respondent Wilson Shealy, Sr.; Eric Steven Bland, of Bland Richter, LLP, of Lexington, for Respondents Renee Shealy Wells, Wilson Shealy, Jr., and Mimi Shealy.

PER CURIAM: David Shealy and his siblings (Siblings) are the adult offspring of Wilson Shealy, Sr. (Father). Father lived on a tract of rural land (the family property) leased from Dominion Energy. David lived there sometimes as well. Over the years, the family property became a repository for lots of items—large and small—including airplanes, vehicles, tools, heavy equipment, and parts.

A dispute arose over these items and has continued after Father's death. Father's death led to much of the disputed personal property being sold so the land would be cleared before it was returned to Dominion. The circuit court granted summary judgment in favor of Father's estate and Siblings on claims David asserted against them. This appeal followed.

We agree that the estate was entitled to summary judgment because David's claims are barred by the Probate Code. But as to Siblings, David's conversion and civil conspiracy claims are genuine disputes with conflicting evidence. We therefore affirm the summary judgment in the estate's favor and reverse the summary judgment for Siblings on David's claims for conversion and conspiracy.

CLAIMS AGAINST FATHER'S ESTATE

The Probate Code establishes the framework for presenting claims against a decedent's estate. See S.C. Code Ann. § 62-3-804 (2022). The key statute (section 62-3-803) is a "nonclaim statute" because it bars a claim unless its terms are followed. In re Estate of Tollison, 320 S.C. 132, 135, 463 S.E.2d 611, 613 (Ct. App. 1995); see also In re Estate of Hover, 407 S.C. 194, 206, 754 S.E.2d 875, 881–82 (2014) ("A statute is a nonclaim statute if there is a clearly evidenced legislative intent in the statute to not merely withhold the remedy, but to take away the right of recovery when a claimant fails to present his or her claim as provided in the statute." (quoting 51 Am. Jur. 2d Limitation of Actions § 3 (2011))). In relevant part, the statute provides that all claims against an estate are barred unless they are "presented" within one year of the decedent's death. S.C. Code Ann. § 62-3-803(a)(1) (2022). However, the Probate Code contains an exception providing "no presentation of a claim is required in regard to matters claimed in proceedings against the decedent which were pending at the time of the decedent's death." § 62-3-804(4).

David argues his claims were "pending" because they had been initiated before Father's death and had not reached a final adjudication. Our precedent forecloses this argument. Before Father died, the parties agreed to strike this lawsuit under Rule 40(j), SCRCP. This court has interpreted the striking of a case under Rule 40(j) as the functional equivalent of a dismissal. See Goodwin v. Landquest Development, LLC, 414 S.C. 623, 630–31, 779 S.E.2d 826, 830–31 (Ct. App. 2015). We do not see how a case could be simultaneously "dismissed" and "pending."

Goodwin analyzed the notes to Rule 40(j) and recognized the rule's purpose was to "substantially revis[e] the procedure for dismissing a case previously found in Rule 40(c)(3)." Id. at 631, 779 S.E.2d at 830 (quoting Rule 40, SCRCP (notes to 1994 amendments)). The court noted that the rule's tolling provision "would not be necessary if striking the case pursuant to Rule 40(j) were not the equivalent of a dismissal." Id. at 631, 779 S.E.2d at 831. As a result, the court determined there was "basis in our law" for considering a stricken case as dismissed. Id. at 630–31, 779 S.E.2d at 830; see also id. at 631–32, 779 S.E.2d at 831 (further explaining the historical basis for considering a case stricken under Rule 40(j) as effectively dismissed). Thus, David's claims were not pending when Father died. The case had been stricken under Rule 40(j) and was not restored until after Father's death.

David next asserts the nonclaim statute does not apply because his claims are not "claims" within the Probate Code's meaning.

A probate "claim" encompasses "debts or demands as existed against the decedent in his or her lifetime and that might have been enforced against him or her by personal actions for the recovery of money." Hover, 407 S.C. at 203, 754 S.E.2d at 880 (quoting 34 C.J.S. Executors & Administrators § 548 (Supp. 2013)). "Stated another way, the term includes every species of liability that the personal representative can be called on to pay out of the general funds of the estate." Id. at 203, 754 S.E.2d at 880 (quoting 34 C.J.S. Executors & Administrators § 548 (Supp. 2013)). However, "claim" excludes "disputes regarding title of a decedent or protected person to specific assets alleged to be included in the estate." S.C. Code Ann. § 62-1-201(4) (2022). David argues that his claims are disputes about who owns the items in question. We do not discount that ownership is an element of conversion, but David's original and amended pleadings did not seek a declaration of title. Instead, he has consistently sought money damages against the estate. See Hover, 407 S.C. at 203, 754 S.E.2d at 880 (finding "personal actions for the recovery of money" qualify as claims (quoting 34 C.J.S. Executors & Administrators § 548 (Supp. 2013)). Thus, though ownership is involved, we do not see David's claims as "title" disputes. They are tort claims seeking damages from the estate.

For these reasons, the circuit court correctly concluded David's claims against the estate were barred by the nonclaim statute.

CLAIMS AGAINST SIBLINGS

The nonclaim statute has no bearing on David's claims against Siblings. David asserted these claims against Siblings in their individual capacities, not as representatives of the estate.

David contends the circuit court misapplied the summary judgment standard by failing to view the evidence in a light most favorable to him as the nonmovant. We agree that the record reflects genuine issues of material facts on David's conversion and civil conspiracy claims. We disagree with respect to David's negligence claim because we see no legal duty supporting a viable negligence claim.

Conversion

"Conversion is the unauthorized assumption and exercise of the right of ownership over goods or personal chattels belonging to another, to the alteration of the condition or the exclusion of the owner's rights." Crane v. Citicorp Nat'l Serv., Inc., 313 S.C. 70, 73, 437 S.E.2d 50

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Rene Wells v. David Shealy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rene-wells-v-david-shealy-scctapp-2026.