res ipsa loquitur doctrine (South Carolina) · Go Syfert
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res ipsa loquitur doctrine in South Carolina

16 South Carolina opinions name it 2 courts 1936–2026 2 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 (10)

CaseFollowedCited
Snow v. City of Columbiagreen
scctapp · 1991 · cited in 3 South Carolina opinions naming this issue, 2010–2025
2 sentences

2025See Snow v. City of Columbia, 305 S.C. 544, 555 , 409 S.E.2d 797, 803 (Ct. App. 1991) (holding the plaintiff's burden of proof in a negligence action "cannot be met by relying on the theory that the thing speaks for itself or that the very fact of injury indicates a failure to exercise reasonable care"); id. ("No inference of negligence arises from the mere fact of injury."); Graham v. Town of Latta, 417 S.C. 164, 186 , 789 S.E.2d 71, 82 (Ct. App. 2016) ("South Carolina does not recognize the doctrine of res ipsa loquitur.").

2025See Snow v. City of Columbia, 305 S.C. 544, 555 , 409 S.E.2d 797, 803 (Ct. App. 1991) (holding the plaintiff's burden of proof in a negligence action "cannot be met by relying on the theory that the thing speaks for itself or that the very fact of injury indicates a failure to exercise reasonable care"); id. ("No inference of negligence arises from the mere fact of injury."); Graham v. Town of Latta, 417 S.C. 164, 186 , 789 S.E.2d 71, 82 (Ct. App. 2016) ("South Carolina does not recognize the doctrine of res ipsa loquitur.").

23
Graham v. Town of Lattagreen
scctapp · 2016 · cited in 2 South Carolina opinions naming this issue, 2025–2026
2 sentences

2026Jail, 337 S.C. 400, 405 , 523 S.E.2d 204, 206 (Ct. App. 1999) ("The absence of any one of these elements renders the cause of action insufficient."); Graham, 417 S.C. at 186 , 789 S.E.2d at 82 ("South Carolina does not recognize the doctrine of res ipsa loquitur."); Kennedy v. Columbia Lumber & Mfg.

2026Jail, 337 S.C. 400, 405 , 523 S.E.2d 204, 206 (Ct. App. 1999) ("The absence of any one of these elements renders the cause of action insufficient."); Graham, 417 S.C. at 186 , 789 S.E.2d at 82 ("South Carolina does not recognize the doctrine of res ipsa loquitur."); Kennedy v. Columbia Lumber & Mfg.

22
King v. J. C. Penney Co.green
sc · 1961 · cited in 2 South Carolina opinions naming this issue, 2006–2014
2 sentences

2014Penny Co., 238 S.C. 336, 339 , 120 S.E.2d 229, 230 (1961) ("[I]t is well settled that the burden rests upon the party to prove negligence."); Moore v. Weinberg, 373 S.C. 209, 221 , 644 S.E.2d 740, 746 (Ct. App. 2007) aff'd, 383 S.C. 583 , 681 S.E.2d 875 (2009) (holding the trial court "must determine, as a matter of law, whether the law recognizes a particular duty[,]" and "[i]f a duty does exist, the jury then determines whether a breach of the duty that resulted in damages occurred"); King, 238 S.C. at 339-40 , 120 S.E.2d at 230 (explaining that South Carolina does not recognize the doctrine

2014Penny Co., 238 S.C. 336, 339 , 120 S.E.2d 229, 230 (1961) ("[I]t is well settled that the burden rests upon the party to prove negligence."); Moore v. Weinberg, 373 S.C. 209, 221 , 644 S.E.2d 740, 746 (Ct. App. 2007) aff'd, 383 S.C. 583 , 681 S.E.2d 875 (2009) (holding the trial court "must determine, as a matter of law, whether the law recognizes a particular duty[,]" and "[i]f a duty does exist, the jury then determines whether a breach of the duty that resulted in damages occurred"); King, 238 S.C. at 339-40 , 120 S.E.2d at 230 (explaining that South Carolina does not recognize the doctrine

22
Chaney v. Burgessgreen
sc · 1965 · cited in 4 South Carolina opinions naming this issue, 1974–2006
2 sentences

2006Without requiring more than proof of an injury, the court would be going directly against our decisions which “uniformly state that the so called doctrine of res ipsa loquitur does not apply in this State.” Chaney , 246 S.C. at 266 , 143 S.E.2d at 523 ; see King v. J.C.

2006Without requiring more than proof of an injury, the court would be going directly against our decisions which “uniformly state that the so called doctrine of res ipsa loquitur does not apply in this State.” Chaney , 246 S.C. at 266 , 143 S.E.2d at 523 ; see King v. J.C.

14
Washington v. Lexington County Jailgreen
scctapp · 1999 · cited in 1 South Carolina opinions naming this issue, 2026–2026
2 sentences

2026Jail, 337 S.C. 400, 405 , 523 S.E.2d 204, 206 (Ct. App. 1999) ("The absence of any one of these elements renders the cause of action insufficient."); Graham, 417 S.C. at 186 , 789 S.E.2d at 82 ("South Carolina does not recognize the doctrine of res ipsa loquitur."); Kennedy v. Columbia Lumber & Mfg.

2026Jail, 337 S.C. 400, 405 , 523 S.E.2d 204, 206 (Ct. App. 1999) ("The absence of any one of these elements renders the cause of action insufficient."); Graham, 417 S.C. at 186 , 789 S.E.2d at 82 ("South Carolina does not recognize the doctrine of res ipsa loquitur."); Kennedy v. Columbia Lumber & Mfg.

11
City of York v. Turner-Murphy Co., Inc.green
scctapp · 1994 · cited in 1 South Carolina opinions naming this issue, 2026–2026
2 sentences

2026Co., 299 S.C. 335, 344 , 384 S.E.2d 730, 736 (1989) ("[A] builder who contracts to construct a dwelling impliedly warrants that the work undertaken will be performed in a careful, diligent, workmanlike manner."); City of York v. Turner-Murphy Co., 317 S.C. 194, 196 , 452 S.E.2d 615, 616-17 (Ct. App. 1994) ("In a professional negligence cause of action, the plaintiff must prove the professional failed to conform to generally recognized and accepted practices in the profession.

2026Co., 299 S.C. 335, 344 , 384 S.E.2d 730, 736 (1989) ("[A] builder who contracts to construct a dwelling impliedly warrants that the work undertaken will be performed in a careful, diligent, workmanlike manner."); City of York v. Turner-Murphy Co., 317 S.C. 194, 196 , 452 S.E.2d 615, 616-17 (Ct. App. 1994) ("In a professional negligence cause of action, the plaintiff must prove the professional failed to conform to generally recognized and accepted practices in the profession.

11
Kennedy v. Columbia Lumber & Manufacturing Co.green
sc · 1989 · cited in 1 South Carolina opinions naming this issue, 2026–2026
2 sentences

2026Co., 299 S.C. 335, 344 , 384 S.E.2d 730, 736 (1989) ("[A] builder who contracts to construct a dwelling impliedly warrants that the work undertaken will be performed in a careful, diligent, workmanlike manner."); City of York v. Turner-Murphy Co., 317 S.C. 194, 196 , 452 S.E.2d 615, 616-17 (Ct. App. 1994) ("In a professional negligence cause of action, the plaintiff must prove the professional failed to conform to generally recognized and accepted practices in the profession.

2026Co., 299 S.C. 335, 344 , 384 S.E.2d 730, 736 (1989) ("[A] builder who contracts to construct a dwelling impliedly warrants that the work undertaken will be performed in a careful, diligent, workmanlike manner."); City of York v. Turner-Murphy Co., 317 S.C. 194, 196 , 452 S.E.2d 615, 616-17 (Ct. App. 1994) ("In a professional negligence cause of action, the plaintiff must prove the professional failed to conform to generally recognized and accepted practices in the profession.

11
Fletcher v. Medical Universitygreen
scctapp · 2010 · cited in 1 South Carolina opinions naming this issue, 2015–2015
2 sentences

2015Univ. of S.C., 390 S.C. 458, 463 , 702 S.E.2d 372, 374 (Ct. App. 2010) ("South Carolina does not recognize the doctrine of res ipsa loquitur." (citation omitted)).

2015Univ. of S.C., 390 S.C. 458, 463 , 702 S.E.2d 372, 374 (Ct. App. 2010) ("South Carolina does not recognize the doctrine of res ipsa loquitur." (citation omitted)).

11
Moore v. Weinberggreen
scctapp · 2007 · cited in 1 South Carolina opinions naming this issue, 2014–2014
2 sentences

2014Penny Co., 238 S.C. 336, 339 , 120 S.E.2d 229, 230 (1961) ("[I]t is well settled that the burden rests upon the party to prove negligence."); Moore v. Weinberg, 373 S.C. 209, 221 , 644 S.E.2d 740, 746 (Ct. App. 2007) aff'd, 383 S.C. 583 , 681 S.E.2d 875 (2009) (holding the trial court "must determine, as a matter of law, whether the law recognizes a particular duty[,]" and "[i]f a duty does exist, the jury then determines whether a breach of the duty that resulted in damages occurred"); King, 238 S.C. at 339-40 , 120 S.E.2d at 230 (explaining that South Carolina does not recognize the doctrine

2014Penny Co., 238 S.C. 336, 339 , 120 S.E.2d 229, 230 (1961) ("[I]t is well settled that the burden rests upon the party to prove negligence."); Moore v. Weinberg, 373 S.C. 209, 221 , 644 S.E.2d 740, 746 (Ct. App. 2007) aff'd, 383 S.C. 583 , 681 S.E.2d 875 (2009) (holding the trial court "must determine, as a matter of law, whether the law recognizes a particular duty[,]" and "[i]f a duty does exist, the jury then determines whether a breach of the duty that resulted in damages occurred"); King, 238 S.C. at 339-40 , 120 S.E.2d at 230 (explaining that South Carolina does not recognize the doctrine

11
Burnett v. FAMILY KINGDOM, INC.green
scctapp · 2010 · cited in 1 South Carolina opinions naming this issue, 2014–2014
2 sentences

2014Penny Co., 238 S.C. 336, 339 , 120 S.E.2d 229, 230 (1961) ("[I]t is well settled that the burden rests upon the party to prove negligence."); Moore v. Weinberg, 373 S.C. 209, 221 , 644 S.E.2d 740, 746 (Ct. App. 2007) aff'd, 383 S.C. 583 , 681 S.E.2d 875 (2009) (holding the trial court "must determine, as a matter of law, whether the law recognizes a particular duty[,]" and "[i]f a duty does exist, the jury then determines whether a breach of the duty that resulted in damages occurred"); King, 238 S.C. at 339-40 , 120 S.E.2d at 230 (explaining that South Carolina does not recognize the doctrine

2014Penny Co., 238 S.C. 336, 339 , 120 S.E.2d 229, 230 (1961) ("[I]t is well settled that the burden rests upon the party to prove negligence."); Moore v. Weinberg, 373 S.C. 209, 221 , 644 S.E.2d 740, 746 (Ct. App. 2007) aff'd, 383 S.C. 583 , 681 S.E.2d 875 (2009) (holding the trial court "must determine, as a matter of law, whether the law recognizes a particular duty[,]" and "[i]f a duty does exist, the jury then determines whether a breach of the duty that resulted in damages occurred"); King, 238 S.C. at 339-40 , 120 S.E.2d at 230 (explaining that South Carolina does not recognize the doctrine

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 (9)

CaseCitedYears
Moore v. Weinberg green
sc · 2009
2 sentences

2014Penny Co., 238 S.C. 336, 339 , 120 S.E.2d 229, 230 (1961) ("[I]t is well settled that the burden rests upon the party to prove negligence."); Moore v. Weinberg, 373 S.C. 209, 221 , 644 S.E.2d 740, 746 (Ct. App. 2007) aff'd, 383 S.C. 583 , 681 S.E.2d 875 (2009) (holding the trial court "must determine, as a matter of law, whether the law recognizes a particular duty[,]" and "[i]f a duty does exist, the jury then determines whether a breach of the duty that resulted in damages occurred"); King, 238 S.C. at 339-40 , 120 S.E.2d at 230 (explaining that South Carolina does not recognize the doctrine

2014Penny Co., 238 S.C. 336, 339 , 120 S.E.2d 229, 230 (1961) ("[I]t is well settled that the burden rests upon the party to prove negligence."); Moore v. Weinberg, 373 S.C. 209, 221 , 644 S.E.2d 740, 746 (Ct. App. 2007) aff'd, 383 S.C. 583 , 681 S.E.2d 875 (2009) (holding the trial court "must determine, as a matter of law, whether the law recognizes a particular duty[,]" and "[i]f a duty does exist, the jury then determines whether a breach of the duty that resulted in damages occurred"); King, 238 S.C. at 339-40 , 120 S.E.2d at 230 (explaining that South Carolina does not recognize the doctrine

12014–2014
McQuillen v. Dobbs green
sc · 1974
2 sentences

1996Inevitably, the rule of civil circumstantial evidence is compared to the doctrine of res ipsa loquitur, and in McQuillen v. Dobbs, 262 S.C. 386 , 204 S.E. (2d) 732 (1974), an exercise in academia is presented: The principles governing the determination of the sufficiency of circumstantial evidence to establish liability were thus stated in Chaney v. Burgess, 246 S.C. 261 , 143 S.E. (2d) 521 (1965): “While our decisions uniformly state that the so called doctrine of res ipsa loquitur does not apply in this State, they have with equal uniformity recognized that negligence may be proved by circum

1996Inevitably, the rule of civil circumstantial evidence is compared to the doctrine of res ipsa loquitur, and in McQuillen v. Dobbs, 262 S.C. 386 , 204 S.E. (2d) 732 (1974), an exercise in academia is presented: The principles governing the determination of the sufficiency of circumstantial evidence to establish liability were thus stated in Chaney v. Burgess, 246 S.C. 261 , 143 S.E. (2d) 521 (1965): “While our decisions uniformly state that the so called doctrine of res ipsa loquitur does not apply in this State, they have with equal uniformity recognized that negligence may be proved by circum

11996–1996
Gilliland v. Pierce Motor Co. green
sc · 1959
1 sentence

1966Gilliland v. Pierce Motor Co., 235 S. C. 268, 111 S. E. (2d) 521 ; Bruno v. Pendleton Realty Co., Inc., 240 S. C. 46, 124 S. E. (2d) 580 , 95 A. L.

11966–1966
Bruno v. Pendleton Realty Co., Inc. green
sc · 1962
1 sentence

1966Gilliland v. Pierce Motor Co., 235 S. C. 268, 111 S. E. (2d) 521 ; Bruno v. Pendleton Realty Co., Inc., 240 S. C. 46, 124 S. E. (2d) 580 , 95 A. L.

11966–1966
Perry v. Carolina Theatre green
sc · 1936
1 sentence

1959Perry v. Carolina Theater, 180 S. C. 130, 185 S. E. 184 .

11959–1959
Evans v. Roberts green
· 1915
1 sentence

1956Another Iowa case was cited, Evans v. Roberts, 172 Iowa 653, 154 N. W. 923 , 926, in which a surgeon, while removing adenoids from a child, negligently cut off a-portion of her tongue.

11956–1956
Eickhoff v. Beard-Laney, Inc. green
· 1942
2 sentences

1954Eickoff v. Beard-Laney, Inc. , 199 S.C. 500 , 20 S.E. (2d) 153 , 141 A.L.R. 1010 .

1954Eickoff v. Beard-Laney, Inc. , 199 S.C. 500 , 20 S.E. (2d) 153 , 141 A.L.R. 1010 .

11954–1954
Delk v. Liggett & Myers Tobacco Co. green
sc · 1936
1 sentence

1940Delk v. Liggett & Myers Tobacco Co., 180 S. C., 436, 186 S. E., 383 , was a case involving a tack in a plug of chewing tobacco not within the Pure Food Act but- held by this Court to be within the general class of food and drink cases insofar as negligence of the manufacturer raises a liability to the ultimate consumer who is injured thereby; verdict was directed for the defendant only on facts not present here, principally the time and opportunity resulting from the carrying of the tobacco in plaintiff’s pocket for the tack to have there gotten into the tobacco; it was said in effect that neg

11940–1940
Pope v. Carolina Theater neutral
sc · 1934
1 sentence

1936Woolworth Co., supra, and in the case of Pope v. Carolina Theater, supra; or it will have to hold that the doctrine of res ipsa loquitur does apply in South Carolina, when it has been repeatedly held that such doctrine does not exist in this State.

11936–1936

Where else courts name it

NY 416 (1897–2026) CA 374 (1909–2026) LA 283 (1931–2025) MO 237 (1907–2017) IL 173 (1900–2025) TX 171 (1912–2025) OH 120 (1923–2026) NC 108 (1910–2026) PA 102 (1911–2025) NJ 87 (1900–2026) KY 83 (1912–2026) GA 80 (1903–2022) WA 73 (1909–2023) CT 72 (1924–2019) MD 72 (1899–2018) IN 69 (1919–2025) TN 64 (1930–2026) IA 60 (1923–2025) MI 59 (1914–2026) FL 58 (1937–2024) KS 45 (1913–2020) OK 44 (1910–2010) MN 42 (1915–2017) AL 42 (1914–2024) MS 41 (1917–2022) CO 39 (1932–2022) WI 38 (1923–2025) NE 37 (1920–2025) WV 37 (1926–2022) AR 36 (1925–2023) DC 35 (1944–2026) AZ 33 (1934–2025) UT 30 (1930–2024) OR 28 (1902–2025) MA 27 (1906–2022) NM 26 (1943–2021) VA 25 (1908–1996) MT 24 (1913–2005) SD 22 (1942–2021) ID 20 (1921–1999) RI 19 (1934–2017) SC 16 (1936–2026) ME 15 (1931–2009) NV 14 (1934–2024) VT 13 (1928–2026) WY 13 (1936–1997) ND 12 (1918–2013) HI 11 (1965–2025) PR 10 (1912–1971) DE 7 (1957–2017) AK 5 (1962–2014) NH 4 (1975–1995)

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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