Ron Christmas v. County of Georgetown

Court of Appeals of South Carolina·Decided August 19, 2026·No. 2023-001454·Unpublished

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

Ron Christmas, Appellant,

v.

County of Georgetown; City of Georgetown; and South Carolina Department of Transportation, Respondents.

Appellate Case No. 2023-001454

Appeal From Georgetown County B. Alex Hyman, Circuit Court Judge

Unpublished Opinion No. 2026-UP-423 Heard December 10, 2025 – Filed August 19, 2026

AFFIRMED AS MODIFIED

Justin O'Toole Lucey, Sohayla Roudsari Townes, and Joshua Fletcher Evans, all of Justin O'Toole Lucey, P.A., of Mount Pleasant, for Appellant.

Michael Warner Battle and Michael Kirk Battle, both of Battle Law Firm, LLC, of Conway, for Respondent County of Georgetown.

Carmen Vaughn Ganjehsani, of Richardson Plowden & Robinson, PA, of Columbia, and Patrick Lewis Huff, of

Aiken, both for Respondent South Carolina Department of Transportation.

Andrew F. Lindemann, of Lindemann Law Firm, P.A., of Columbia, for Respondent City of Georgetown.

PER CURIAM: Ron Christmas appeals the trial court's grant of directed verdicts to the County of Georgetown (the County), the City of Georgetown (the City), and the South Carolina Department of Transportation (SCDOT) (collectively, Respondents) on his causes of action for negligence, inverse condemnation, violation of section 5-31-450 of the South Carolina Code (2004), and writ of mandamus. Christmas argues the trial court erred in restricting his expert witness's qualifications, limiting the testimony of his expert witness and himself, and granting directed verdicts on all causes of action. We affirm as modified.

1. Christmas argues the trial court erred concerning the testimony of Christmas's expert witness, Robert L. Castles Jr., in several ways. First, Christmas asserts the trial court erred by failing to qualify Castles as an expert witness in hydrology. The trial court qualified Castles as an expert in civil engineering and forensic engineering but not hydrology. We do not address this issue on appeal because Christmas acquiesced in the trial court's ruling. At trial, Christmas sought to qualify Castles as an expert in hydrology, which Respondents opposed. Christmas responded he did not need Castles in that area and modified the qualification to "an expert in civil engineering with a focus on drainage and forensics." See State v. Mitchell, 330 S.C. 189, 195, 498 S.E.2d 642, 645 (1998) (providing that when an appellant acquiesces in a trial court's ruling, that issue is procedurally barred on appeal); Hollins v. Wal-Mart Stores, Inc., 381 S.C. 245, 251, 672 S.E.2d 805, 808 (Ct. App. 2008) (noting that because the appellant acquiesced in the trial court's ruling, she failed to preserve the issue for appellate review).

Christmas also contends the trial court did not explain the limitation on Castles's hydrology testimony—what would and would not be permitted—and the trial court made no effort to understand the opinions and expertise Castles would offer on the subject. This argument is unpreserved because Christmas did not request clarification during the trial and raised it for the first time on appeal. See Ellie, Inc. v. Miccichi, 358 S.C. 78, 102, 594 S.E.2d 485, 498 (Ct. App. 2004) ("[A]n issue cannot be raised for the first time on appeal[] but must have been raised to and ruled upon by the trial court to be preserved for appellate review." (quoting Staubes v. City of Folly Beach, 339 S.C. 406, 412, 529 S.E.2d 543, 546 (2000))).

Further, the testimony Christmas proffered from Castles when seeking to offer him as an expert in hydrology was not general hydrology information. It was information specific to this case but not based on his own work. It was taken from the report of another person who Christmas asserted was an expert for the settling codefendant and would not testify at trial. Christmas did not argue or sufficiently demonstrate the information contained in the report was the type of information normally relied upon by experts in Castles's field in rendering an opinion. See Watson v. Ford Motor Co., 389 S.C. 434, 447, 699 S.E.2d 169, 176 (2010) ("The qualification of a witness as an expert is within the trial court's discretion, and this [c]ourt will not reverse that decision absent an abuse of discretion."); Johnson v. Sam Eng. Grading, Inc., 412 S.C. 433, 448, 772 S.E.2d 544, 551 (Ct. App. 2015) ("An abuse of discretion occurs when the ruling is based on an error of law or a factual conclusion that is without evidentiary support." (quoting Menne v. Keowee Key Prop. Owners' Ass'n, 368 S.C. 557, 568, 629 S.E.2d 690, 696 (Ct. App. 2006))); Hundley ex rel. Hundley v. Rite Aid of S.C., Inc., 339 S.C. 285, 294-95, 529 S.E.2d 45, 50 (Ct. App. 2000) ("[G]enerally under Rule 602, SCRE, '[a] witness may not testify to a matter unless evidence is introduced sufficient to support a finding that the witness has personal knowledge of the matter.'" (second alteration in original)); id. at 295, 529 S.E.2d at 50 ("An expert witness may state an opinion based on facts not within his firsthand knowledge."); id. ("[An expert] may base his opinion on information, whether or not admissible, made available to him before the hearing if the information is of the type reasonably relied upon in the field to make opinions."); In re the Care & Treatment of Bilton, 432 S.C. 157, 167, 851 S.E.2d 442, 446 (Ct. App. 2020) ("[D]ue process does not allow a testifying expert to be a pipeline for someone else's scientific work to be admitted into evidence without a baseline demonstration of reliability."). Accordingly, the trial court did not abuse its discretion in not allowing Castles to testify about hydrology.

Christmas also asserts the trial court erred in limiting Castles's testimony that trucks used in the park renovation caused or contributed to subsidence of the road. The trial court allowed Castles to testify that heavy trucks could cause subsidence of the road but did not let him testify that the trucks used to renovate the park actually caused the subsidence. The trial court determined Christmas had not provided evidence to show if the trucks used in the renovation caused the subsistence. The trial court did not abuse its discretion in this ruling. See Davis v. Traylor, 340 S.C. 150, 157, 530 S.E.2d 385, 388 (Ct. App. 2000) ("The trial court has broad discretion in the admission or rejection of evidence and will not be overturned unless it abuses that discretion."); Johnson, 412 S.C. at 448, 772 S.E.2d at 551 ("An abuse of discretion occurs when the ruling is based on an error of law or a factual conclusion that is without evidentiary support." (quoting Menne, 368 S.C. at 568, 629 S.E.2d at 696)); Conway v. Charleston Lincoln Mercury Inc., 363 S.C. 301, 307, 609 S.E.2d 838, 842 (Ct. App. 2005) ("To warrant a reversal based on the admission of evidence, the appellant must show both error and resulting prejudice."); Marlowe v. S.C. Dep't of Transp., 446 S.C. 309, 317, 919 S.E.2d 553, 557 (2025) ("[B]efore expert testimony is admissible upon the question of the causal connection between plaintiff's injuries and the acts of the defendant, the testimony must satisfy the 'most probably' rule." (alteration in original) (quoting Baughman v. Am. Tel. & Tel. Co., 306 S.C. 101, 111, 410 S.E.2d 537, 543 (1991))).

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