clear and convincing evidentiary standard in South Carolina

2021See Oskin v. Johnson, 400 S.C. 390, 396 , 735 S.E.2d 459, 463 (2012) ("A clear and convincing evidentiary standard governs fraudulent conveyance claims brought under the Statue of Elizabeth."); id. ("An action to set aside a conveyance under the Statute of Elizabeth is an equitable action, and a de novo standard of review applies."); § 27-23-10(A) ("Every . . . conveyance of lands . . . which may be had or made to or for any intent or purpose to delay, hinder, or defraud creditors and others of their just and lawful actions, suits, debts, accounts, damages, penalties, and forfeitures must be d

2021See Oskin v. Johnson, 400 S.C. 390, 396 , 735 S.E.2d 459, 463 (2012) ("A clear and convincing evidentiary standard governs fraudulent conveyance claims brought under the Statue of Elizabeth."); id. ("An action to set aside a conveyance under the Statute of Elizabeth is an equitable action, and a de novo standard of review applies."); § 27-23-10(A) ("Every . . . conveyance of lands . . . which may be had or made to or for any intent or purpose to delay, hinder, or defraud creditors and others of their just and lawful actions, suits, debts, accounts, damages, penalties, and forfeitures must be d

2021See Oskin v. Johnson, 400 S.C. 390, 396 , 735 S.E.2d 459, 463 (2012) ("A clear and convincing evidentiary standard governs fraudulent conveyance claims brought under the Statue of Elizabeth."); id. ("An action to set aside a conveyance under the Statute of Elizabeth is an equitable action, and a de novo standard of review applies."); § 27-23-10(A) ("Every . . . conveyance of lands . . . which may be had or made to or for any intent or purpose to delay, hinder, or defraud creditors and others of their just and lawful actions, suits, debts, accounts, damages, penalties, and forfeitures must be d

2021See Oskin v. Johnson, 400 S.C. 390, 396 , 735 S.E.2d 459, 463 (2012) ("A clear and convincing evidentiary standard governs fraudulent conveyance claims brought under the Statue of Elizabeth."); id. ("An action to set aside a conveyance under the Statute of Elizabeth is an equitable action, and a de novo standard of review applies."); § 27-23-10(A) ("Every . . . conveyance of lands . . . which may be had or made to or for any intent or purpose to delay, hinder, or defraud creditors and others of their just and lawful actions, suits, debts, accounts, damages, penalties, and forfeitures must be d

2021See Oskin v. Johnson, 400 S.C. 390, 396 , 735 S.E.2d 459, 463 (2012) ("A clear and convincing evidentiary standard governs fraudulent conveyance claims brought under the Statue of Elizabeth."); id. ("An action to set aside a conveyance under the Statute of Elizabeth is an equitable action, and a de novo standard of review applies."); § 27-23-10(A) ("Every . . . conveyance of lands . . . which may be had or made to or for any intent or purpose to delay, hinder, or defraud creditors and others of their just and lawful actions, suits, debts, accounts, damages, penalties, and forfeitures must be d

2021See Oskin v. Johnson, 400 S.C. 390, 396 , 735 S.E.2d 459, 463 (2012) ("A clear and convincing evidentiary standard governs fraudulent conveyance claims brought under the Statue of Elizabeth."); id. ("An action to set aside a conveyance under the Statute of Elizabeth is an equitable action, and a de novo standard of review applies."); § 27-23-10(A) ("Every . . . conveyance of lands . . . which may be had or made to or for any intent or purpose to delay, hinder, or defraud creditors and others of their just and lawful actions, suits, debts, accounts, damages, penalties, and forfeitures must be d

2018Code Ann. § 27-23-10 (A) (2007) ("Every gift, grant, alienation, bargain, transfer, and conveyance of lands, tenements, or hereditaments, goods and chattels or any of them, or of any lease, rent, commons, or other profit or charge out of the same, by writing or otherwise, and every bond, suit, judgment, and execution which may be had or made to or for any intent or purpose to delay, hinder, or defraud creditors and others of their just and lawful actions, suits, debts, accounts, damages, penalties, and forfeitures must be deemed and taken . . . to be clearly and utterly void . . . ."); Oskin,

2018Code Ann. § 27-23-10 (A) (2007) ("Every gift, grant, alienation, bargain, transfer, and conveyance of lands, tenements, or hereditaments, goods and chattels or any of them, or of any lease, rent, commons, or other profit or charge out of the same, by writing or otherwise, and every bond, suit, judgment, and execution which may be had or made to or for any intent or purpose to delay, hinder, or defraud creditors and others of their just and lawful actions, suits, debts, accounts, damages, penalties, and forfeitures must be deemed and taken . . . to be clearly and utterly void . . . ."); Oskin,

2018As to whether the master-in-equity erred in finding the Statute of Elizabeth rendered the transfer of funds between MD Medical and Mathis null and void: Tiger, Inc. v. Fisher Agro, Inc., 301 S.C. 229, 237 , 391 S.E.2d 538, 543 (1989) ("Our scope of review for a case heard by a [m]aster-in-[e]quity who enters a final judgment is the same as that for review of a case heard by a circuit court without a jury."); Oskin v. Johnson, 400 S.C. 390, 396-97 , 735 S.E.2d 459, 463 (2012) ("A clear and convincing evidentiary standard governs fraudulent conveyance claims brought under the Statute of Elizabet

2018As to whether the master-in-equity erred in finding the Statute of Elizabeth rendered the transfer of funds between MD Medical and Mathis null and void: Tiger, Inc. v. Fisher Agro, Inc., 301 S.C. 229, 237 , 391 S.E.2d 538, 543 (1989) ("Our scope of review for a case heard by a [m]aster-in-[e]quity who enters a final judgment is the same as that for review of a case heard by a circuit court without a jury."); Oskin v. Johnson, 400 S.C. 390, 396-97 , 735 S.E.2d 459, 463 (2012) ("A clear and convincing evidentiary standard governs fraudulent conveyance claims brought under the Statute of Elizabet

2018Code Ann. § 27-23-10 (A) (2007) ("Every gift, grant, alienation, bargain, transfer, and conveyance of lands, tenements, or hereditaments, goods and chattels or any of them, or of any lease, rent, commons, or other profit or charge out of the same, by writing or otherwise, and every bond, suit, judgment, and execution which may be had or made to or for any intent or purpose to delay, hinder, or defraud creditors and others of their just and lawful actions, suits, debts, accounts, damages, penalties, and forfeitures must be deemed and taken . . . to be clearly and utterly void . . . ."); Oskin,

2018Code Ann. § 27-23-10 (A) (2007) ("Every gift, grant, alienation, bargain, transfer, and conveyance of lands, tenements, or hereditaments, goods and chattels or any of them, or of any lease, rent, commons, or other profit or charge out of the same, by writing or otherwise, and every bond, suit, judgment, and execution which may be had or made to or for any intent or purpose to delay, hinder, or defraud creditors and others of their just and lawful actions, suits, debts, accounts, damages, penalties, and forfeitures must be deemed and taken . . . to be clearly and utterly void . . . ."); Oskin,

2016PER CURIAM: Affirmed pursuant to Rule 220(b), SCACR, and the following authorities: Judy v. Judy, 403 S.C. 203, 207-08 , 742 S.E.2d 672, 675 (Ct. App. 2013) ("A clear and convincing evidentiary standard governs fraudulent conveyance claims brought under the Statute of Elizabeth.

2016PER CURIAM: Affirmed pursuant to Rule 220(b), SCACR, and the following authorities: Judy v. Judy, 403 S.C. 203, 207-08 , 742 S.E.2d 672, 675 (Ct. App. 2013) ("A clear and convincing evidentiary standard governs fraudulent conveyance claims brought under the Statute of Elizabeth.

2016An action to set aside a conveyance under the Statute of Elizabeth is an equitable action, and a de novo standard of review applies." (quoting Oskin v. Johnson, 400 S.C. 390, 396 , 735 S.E.2d 459, 463 (2012))); Pinckney v. Warren, 344 S.C. 382, 387 , 544 S.E.2d 620, 623 (2001) ("In an appeal from an action in equity, [an appellate court] has jurisdiction to find facts in accordance with its own view of the preponderance of the evidence."); id. ("However, this broad scope of review does not require an appellate court to disregard the findings below or ignore the fact that the trial judge is in

2016An action to set aside a conveyance under the Statute of Elizabeth is an equitable action, and a de novo standard of review applies." (quoting Oskin v. Johnson, 400 S.C. 390, 396 , 735 S.E.2d 459, 463 (2012))); Pinckney v. Warren, 344 S.C. 382, 387 , 544 S.E.2d 620, 623 (2001) ("In an appeal from an action in equity, [an appellate court] has jurisdiction to find facts in accordance with its own view of the preponderance of the evidence."); id. ("However, this broad scope of review does not require an appellate court to disregard the findings below or ignore the fact that the trial judge is in

2013Co., 381 S.C. 326, 330-31 , 673 S.E.2d 801, 803 (2009) (stating that in cases requiring a heightened burden of proof, the non-moving party must submit more than a mere scintilla of evidence to withstand a motion for summary judgment).

2013Co., 381 S.C. 326, 330-31 , 673 S.E.2d 801, 803 (2009) (stating that in cases requiring a heightened burden of proof, the non-moving party must submit more than a mere scintilla of evidence to withstand a motion for summary judgment).

2012Co., 331 S.C. 466, 471 , 498 S.E.2d 858, 860 (1998) (citations omitted).

2012Co., 331 S.C. 466, 471 , 498 S.E.2d 858, 860 (1998) (citations omitted).

2009See, e.g., State v. Cutro, 332 S.C. 100, 110 , 504 S.E.2d 324, 329 (1998) (“A review of the record reveals there is ample evidence to uphold the trial court’s ruling that the prior bad acts were proven by clear and convincing evidence.”); Berry v. Ianuario, 286 S.C. 522, 525 , 335 S.E.2d 250, 251 (Ct.App.1985) (“We find sufficient evidence in the record ... to meet the ‘clear and convincing’ evidence standard.”).

2009See, e.g., State v. Cutro, 332 S.C. 100, 110 , 504 S.E.2d 324, 329 (1998) (“A review of the record reveals there is ample evidence to uphold the trial court’s ruling that the prior bad acts were proven by clear and convincing evidence.”); Berry v. Ianuario, 286 S.C. 522, 525 , 335 S.E.2d 250, 251 (Ct.App.1985) (“We find sufficient evidence in the record ... to meet the ‘clear and convincing’ evidence standard.”).

2009See, e.g., State v. Cutro, 332 S.C. 100, 110 , 504 S.E.2d 324, 329 (1998) (“A review of the record reveals there is ample evidence to uphold the trial court’s ruling that the prior bad acts were proven by clear and convincing evidence.”); Berry v. Ianuario, 286 S.C. 522, 525 , 335 S.E.2d 250, 251 (Ct.App.1985) (“We find sufficient evidence in the record ... to meet the ‘clear and convincing’ evidence standard.”).

2009See, e.g., State v. Cutro, 332 S.C. 100, 110 , 504 S.E.2d 324, 329 (1998) (“A review of the record reveals there is ample evidence to uphold the trial court’s ruling that the prior bad acts were proven by clear and convincing evidence.”); Berry v. Ianuario, 286 S.C. 522, 525 , 335 S.E.2d 250, 251 (Ct.App.1985) (“We find sufficient evidence in the record ... to meet the ‘clear and convincing’ evidence standard.”).