empty chair defense (South Carolina) · Go Syfert
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empty chair defense in South Carolina

5 South Carolina opinions name it 2 courts 2017–2023 3 in the last five years

The cases below were cited by South Carolina courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Smith v. Tiffanygreen
sc · 2017 · cited in 3 South Carolina opinions naming this issue, 2021–2023
2 sentences

2022In differentiating between Scapa's request to admit the bankruptcy claims with an attempt to establish an empty-chair defense, the court noted the empty chair defense is an attempt to introduce direct evidence 5 419 S.C. 548 , 799 S.E.2d 479 (2017). of the liability of a bankrupt company for the injuries Stewart suffered—evidence the court would admit.

2022In differentiating between Scapa's request to admit the bankruptcy claims with an attempt to establish an empty-chair defense, the court noted the empty chair defense is an attempt to introduce direct evidence 5 419 S.C. 548 , 799 S.E.2d 479 (2017). of the liability of a bankrupt company for the injuries Stewart suffered—evidence the court would admit.

23
Machin v. Carus Corp.green
sc · 2017 · cited in 1 South Carolina opinions naming this issue, 2022–2022
2 sentences

2022In seeking to establish an empty-chair defense, a defendant must assign fault for the plaintiff's injury to another party by providing evidence to the fact-finder that is sufficient for it to determine whether the party's "actions were the cause of the plaintiff's injuries." Machin v. Carus Corp., 419 S.C. 527 , 542–43, 799 S.E.2d 468, 476 (2017).

2022In seeking to establish an empty-chair defense, a defendant must assign fault for the plaintiff's injury to another party by providing evidence to the fact-finder that is sufficient for it to determine whether the party's "actions were the cause of the plaintiff's injuries." Machin v. Carus Corp., 419 S.C. 527 , 542–43, 799 S.E.2d 468, 476 (2017).

11
Riley Ex Rel. Estate of Riley v. Ford Motor Co.green
sc · 2015 · cited in 1 South Carolina opinions naming this issue, 2021–2021
2 sentences

2021See Riley v. Ford Motor Co., 414 S.C. 185 , 197–98, 777 S.E.2d 824, 831 (2015) (finding the defendant improperly extracted a benefit from the settlement between the plaintiff and a prior codefendant when the court reapportioned the allocation of settlement proceeds between the settling parties in a manner that decreased the defendant's liability).

2021See Riley v. Ford Motor Co., 414 S.C. 185 , 197–98, 777 S.E.2d 824, 831 (2015) (finding the defendant improperly extracted a benefit from the settlement between the plaintiff and a prior codefendant when the court reapportioned the allocation of settlement proceeds between the settling parties in a manner that decreased the defendant's liability).

11
Carriere v. Cominco Alaska, Inc.green
akd · 1993 · cited in 1 South Carolina opinions naming this issue, 2017–2017
1 sentence

2017See, e.g., Carriere v. Cominco Alaska, Inc., 823 F.Supp. 680, 692 (D.

11
Smith v. Widenergreen
scctapp · 2012 · cited in 1 South Carolina opinions naming this issue, 2017–2017
2 sentences

2017See Smith v. Widener, 397 S.C. 468, 472 , 724 S.E.2d 188, 190 (Ct. App. 2012) (holding a nonsettling defendant’s right to setoff arises by operation of law, and it is not within the discretion of the trial court to apply setoff).

2017See Smith v. Widener, 397 S.C. 468, 472 , 724 S.E.2d 188, 190 (Ct. App. 2012) (holding a nonsettling defendant’s right to setoff arises by operation of law, and it is not within the discretion of the trial court to apply setoff).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in South Carolina. Read the followed side critically anyway.

Also cited on this issue (1)

CaseCitedYears
Chester v. South Carolina Department of Public Safety green
sc · 2010
1 sentence

2023Id. [A] critical feature of the [Act] is the codification of the empty chair defense—a defendant 'retain[s] the right to assert another potential tortfeasor, whether a party or not, contributed to the alleged injury or damages'—which necessarily contemplates lawsuits in which an allegedly culpable person or entity is not a party to the litigation (hence the chair in question being 'empty').

12023–2023

Statutes the citing opinions construe

SC § S.C. Code Ann. § 15-38-15 (5) SC § S.C. Code Ann. § 15-38-50 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

RI 12 (1986–2026) SC 5 (2017–2023) TX 2 (2001–2011)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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