Wells Fargo Bank v. James E. Turner

CourtCourt of Appeals of South Carolina
DecidedJuly 1, 2026
Docket2023-001054
StatusUnpublished

This text of Wells Fargo Bank v. James E. Turner (Wells Fargo Bank v. James E. Turner) 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
Wells Fargo Bank v. James E. Turner, (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

Wells Fargo Bank, National Association, not in its individual or banking capacity, but solely as Trustee on behalf of Green Tree Mortgage Trust 2005-HE1, Respondent,

v.

James E. Turner a/k/a James Turner, Sr, Appellant.

Appellate Case No. 2023-001054

Appeal From Richland County Joseph M. Strickland, Master-in-Equity

Unpublished Opinion No. 2026-UP-331 Submitted June 1, 2026 – Filed July 1, 2026

AFFIRMED

Glenn Walters, Sr., of Glenn Walters & Associates, PA, of Orangeburg, for Appellant.

Theodore von Keller, B. Lindsay Crawford, III, and Jason Mark Hunter, all of Crawford & von Keller, LLC; and Christopher Brian Lusk, of Jeffcoat Law Firm, LLC, all of Columbia, for Respondent. PER CURIAM: James E. Turner appeals the master-in-equity's order of foreclosure and sale in favor of Wells Fargo Bank, National Association, not in its individual or banking capacity, but solely as Trustee on behalf of Green Tree Mortgage Trust 2005-HEI (Wells Fargo) on its foreclosure action.1. On appeal, Turner argues (1) the master erred in allowing Wells Fargo's litigation support employee to testify concerning the information contained in the loan document, (2) the admission of hearsay testimony prejudiced the outcome of the case, (3) Wells Fargo failed to establish a prima facie case of foreclosure, and (4) the master erred in setting aside the lost mortgage satisfaction. We affirm pursuant to Rule 220(b), SCACR.

First, we hold the master did not abuse its discretion in permitting the witness to testify about the information contained within the loan documents because he was a qualified witness and laid the proper foundation pursuant to Rule 803(6) of the South Carolina Rules of Evidence. See Rawlinson Rd. Homeowners Ass'n, Inc. v. Jackson, 395 S.C. 25, 36, 716 S.E.2d 337, 344 (Ct. App. 2011) ("Generally, the admission or exclusion of testimony is a matter within the trial court's sound discretion and will not be disturbed on appeal absent an abuse of that discretion."). The witness was qualified to testify about the documents because (1) he was the authorized representative of Shellpoint Mortgage Services (Shellpoint) for the loan documents; (2) he was familiar with Shellpoint's, Green Tree Financial Servicing Corporation's (Green Tree's), and Ditech Financial LLC's (Ditech's) procedures and documents, which were all maintained throughout the life of the loans; and (3) the witness conveyed information from a person "with knowledge" at the time the records were created. See Deep Keel, LLC v. Atl. Priv. Equity Grp., LLC, 413 S.C. 58, 73, 773 S.E.2d 607, 615 (Ct. App. 2015) ("[A] witness [may be] qualified to testify about a business record, despite the fact he or she did not personally participate in the creation of the record and was not the custodian 'at or near the time' the record was made." (quoting Twelfth RMA Partners, L.P. v. Nat'l Safe Corp., 335 S.C. 635, 642, 518 S.E.2d 44, 48 (Ct. App. 1999))); id. (determining a witness who "studied the manner in which [the banks] maintained the records before he purchased the note" was a qualified witness). We also hold the witness laid the proper foundation to meet Rule 803(6) requirements because he testified the documents were made at or near the time of the events occurring within them, were transmitted by a person with knowledge of the information, were kept during the course of regularly-conducted business activities, and the witness was qualified to testify regarding the documents and the master did not find him untrustworthy.

1 The foreclosure action concerned a note and mortgage from 1996 (Note 1 and Mortgage 1) and from 1997 (Note 2 and Mortgage 2). See Deep Keel, LLC, 413 S.C. at 73, 773 S.E.2d at 615 ("However, establishing that a witness is qualified to testify about a business record does not automatically lead to admission of that record. The qualified witness must then lay the foundation to meet the requirements of Rule 803(6) and section 19-5-510 [of the South Carolina Code (2014)]."); Ex parte Dep't of Health & Env't Control, 350 S.C. 243, 249-50, 565 S.E.2d 293, 297 (2002) ("Rule 803(6) . . . provides that memorandum, reports, etc. in any form, of acts, conditions, or diagnoses, are admissible as longs as they are (1) prepared near the time of the event recorded; (2) prepared by someone with or from information transmitted by a person with knowledge; (3) prepared in the regular course of business; (4) identified by a qualified witness who can testify regarding the mode of preparation of the record; and (5) found to be trustworthy by the court."); § 19-5-510 ("A record of an act, condition or event shall, insofar as relevant, be competent evidence if the custodian or other qualified witness testifies to its identity and the mode of its preparation, and if it was made in the regular course of business, at or near the time of the act, condition or event and if, in the opinion of the court, the sources of information, method and time of preparation were such as to justify its admission."). Although Turner asserts the loan payment history documents were not admitted into evidence due to Wells Fargo's inadvertence, the master permitted their admission on redirect examination, which was within the discretion of the master. See Levy v. Outdoor Resorts of S.C., Inc., 304 S.C. 427, 431, 405 S.E.2d 387, 390 (1991) ("The scope of redirect examination is a matter within the discretion of the [master]."). Additionally, Turner opened the door to the entry of the documentation by demanding the witness show the payment history. See Rule 611(d), SCRE ("A witness may be re-examined as to the same matters to which he testified only in the discretion of the court, but without exception he may be re-examined as to any new matter brought out during cross-examination."). Therefore, because the witness was a qualified witness, laid the foundation for the entry of the records, and the records were in evidence, the master did not err in permitting the witness to testify regarding the contents of the records. See Deep Keel, LLC, 413 S.C. at 72, 773 S.E.2d at 614 ("Rule 803(6) does not apply to admit live testimony offered to prove the contents of a record containing hearsay when that record is not offered in evidence." (emphasis added)).2

2 Because we hold the master did not err in permitting the witness's testimony, we need not address Turner's issues two and three as to whether the admission of the hearsay testimony prejudiced him or that without the testimony, Wells Fargo failed to prove a prima facie case of foreclosure. See Futch v. McAllister Towing of Georgetown, Inc., 335 S.C. 598, 613, 518 S.E.2d 591, 598 (1999) (explaining an Second, we hold the master did not err in setting aside the lost mortgage satisfaction. See Hayne Fed. Credit Union v. Bailey, 327 S.C. 242, 248, 489 S.E.2d 472, 475 (1997) ("A mortgage foreclosure is an action in equity."); Charleston Elec. Servs., Inc.

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Related

Ex Parte Dept. of Health & Env. Control
565 S.E.2d 293 (Supreme Court of South Carolina, 2002)
Wilder Corp. v. Wilke
497 S.E.2d 731 (Supreme Court of South Carolina, 1998)
Futch v. McAllister Towing of Georgetown, Inc.
518 S.E.2d 591 (Supreme Court of South Carolina, 1999)
Twelfth RMA Partners, L.P. v. National Safe Corp.
518 S.E.2d 44 (Court of Appeals of South Carolina, 1999)
Hayne Federal Credit Union v. Bailey
489 S.E.2d 472 (Supreme Court of South Carolina, 1997)
Rawlinson Road Homeowners Ass'n v. Jackson
716 S.E.2d 337 (Court of Appeals of South Carolina, 2011)
Williams & Co. v. Paysinger
15 S.C. 171 (Supreme Court of South Carolina, 1881)
Charleston Elec. Servs., Inc. v. Rahall
831 S.E.2d 122 (Court of Appeals of South Carolina, 2019)
Levy v. Outdoor Resorts of South Carolina, Inc.
405 S.E.2d 387 (Supreme Court of South Carolina, 1991)
Deep Keel, LLC v. Atlantic Private Equity Group, LLC
773 S.E.2d 607 (Court of Appeals of South Carolina, 2015)

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Bluebook (online)
Wells Fargo Bank v. James E. Turner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wells-fargo-bank-v-james-e-turner-scctapp-2026.