exhaustion requirement (South Carolina) · Go Syfert
← South Carolina issues

exhaustion requirement in South Carolina

12 South Carolina opinions name it 2 courts 1990–2024 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 (11)

CaseFollowedCited
Law v. South Carolina Department of Correctionsgreen
sc · 2006 · cited in 3 South Carolina opinions naming this issue, 2012–2023
2 sentences

2023Dep't of Corr., 368 S.C. 424, 438 , 629 S.E.2d 642, 650 (2006)); see also Stanton, 309 S.C. at 128 , 420 S.E.2d at 503 (holding the party seeking to avoid the exhaustion requirement has the burden of showing "that as a matter of law, he was not required to exhaust administrative remedies or that the [circuit court]'s ruling was based upon facts for which there is no evidentiary support"). 9 Cox does not explain what aspect of Respondents' administrative remedy argument raises a question of statutory construction.

2023Dep't of Corr., 368 S.C. 424, 438 , 629 S.E.2d 642, 650 (2006)); see also Stanton, 309 S.C. at 128 , 420 S.E.2d at 503 (holding the party seeking to avoid the exhaustion requirement has the burden of showing "that as a matter of law, he was not required to exhaust administrative remedies or that the [circuit court]'s ruling was based upon facts for which there is no evidentiary support"). 9 Cox does not explain what aspect of Respondents' administrative remedy argument raises a question of statutory construction.

33
Stanton v. Town of Pawleys Islandgreen
sc · 1992 · cited in 2 South Carolina opinions naming this issue, 2023–2023
2 sentences

2023Dep't of Corr., 368 S.C. 424, 438 , 629 S.E.2d 642, 650 (2006)); see also Stanton, 309 S.C. at 128 , 420 S.E.2d at 503 (holding the party seeking to avoid the exhaustion requirement has the burden of showing "that as a matter of law, he was not required to exhaust administrative remedies or that the [circuit court]'s ruling was based upon facts for which there is no evidentiary support"). 9 Cox does not explain what aspect of Respondents' administrative remedy argument raises a question of statutory construction.

2023Dep't of Corr., 368 S.C. 424, 438 , 629 S.E.2d 642, 650 (2006)); see also Stanton, 309 S.C. at 128 , 420 S.E.2d at 503 (holding the party seeking to avoid the exhaustion requirement has the burden of showing "that as a matter of law, he was not required to exhaust administrative remedies or that the [circuit court]'s ruling was based upon facts for which there is no evidentiary support"). 9 Cox does not explain what aspect of Respondents' administrative remedy argument raises a question of statutory construction.

22
Responsible Economic Development v. South Carolina Department of Health & Environmental Controlgreen
sc · 2007 · cited in 1 South Carolina opinions naming this issue, 2024–2024
2 sentences

2024Id. at 553 , 641 S.E.2d at 428 (citations omitted).

2024Id. at 553 , 641 S.E.2d at 428 (citations omitted).

11
Brackenbrook North Charleston, LP v. County of Charlestongreen
sc · 2004 · cited in 1 South Carolina opinions naming this issue, 2023–2023
2 sentences

2023See id. at 396 , 602 S.E.2d at 43 .

2023See id. at 396 , 602 S.E.2d at 43 .

11
Tri-County Ice and Fuel Co. v. Palmetto Ice Co.green
sc · 1991 · cited in 1 South Carolina opinions naming this issue, 2012–2012
2 sentences

2012Dep't of Revenue, 342 S.C. 34, 39 , 535 S.E.2d 642, 645 (2000) (finding that "the mere presence of a constitutional issue does not excuse the exhaustion requirement where there are other issues in controversy"); Law, 368 S.C. at 438 , 629 S.E.2d at 650 (stating that whether to require the plaintiff to exhaust administrative remedies is a matter within the sound discretion of the trial judge and will not be disturbed on appeal absent an abuse of discretion (citing Andrews Bearing Corp., 261 S.C. at 536 , 201 S.E.2d at 243 ; Tri-County Ice & Fuel Co. v. Palmetto Ice Co., 303 S.C. 237, 242 , 399

2012Dep't of Revenue, 342 S.C. 34, 39 , 535 S.E.2d 642, 645 (2000) (finding that "the mere presence of a constitutional issue does not excuse the exhaustion requirement where there are other issues in controversy"); Law, 368 S.C. at 438 , 629 S.E.2d at 650 (stating that whether to require the plaintiff to exhaust administrative remedies is a matter within the sound discretion of the trial judge and will not be disturbed on appeal absent an abuse of discretion (citing Andrews Bearing Corp., 261 S.C. at 536 , 201 S.E.2d at 243 ; Tri-County Ice & Fuel Co. v. Palmetto Ice Co., 303 S.C. 237, 242 , 399

11
Video Gaming Consultants, Inc. v. South Carolina Department of Revenuegreen
sc · 2000 · cited in 1 South Carolina opinions naming this issue, 2012–2012
2 sentences

2012Dep't of Revenue, 342 S.C. 34, 39 , 535 S.E.2d 642, 645 (2000) (finding that "the mere presence of a constitutional issue does not excuse the exhaustion requirement where there are other issues in controversy"); Law, 368 S.C. at 438 , 629 S.E.2d at 650 (stating that whether to require the plaintiff to exhaust administrative remedies is a matter within the sound discretion of the trial judge and will not be disturbed on appeal absent an abuse of discretion (citing Andrews Bearing Corp., 261 S.C. at 536 , 201 S.E.2d at 243 ; Tri-County Ice & Fuel Co. v. Palmetto Ice Co., 303 S.C. 237, 242 , 399

2012Dep't of Revenue, 342 S.C. 34, 39 , 535 S.E.2d 642, 645 (2000) (finding that "the mere presence of a constitutional issue does not excuse the exhaustion requirement where there are other issues in controversy"); Law, 368 S.C. at 438 , 629 S.E.2d at 650 (stating that whether to require the plaintiff to exhaust administrative remedies is a matter within the sound discretion of the trial judge and will not be disturbed on appeal absent an abuse of discretion (citing Andrews Bearing Corp., 261 S.C. at 536 , 201 S.E.2d at 243 ; Tri-County Ice & Fuel Co. v. Palmetto Ice Co., 303 S.C. 237, 242 , 399

11
Buist v. Hugginsgreen
sc · 2006 · cited in 1 South Carolina opinions naming this issue, 2007–2007
2 sentences

2007Put simply, we agree with the Court of Appeals' observation that "[h]ad the *269 Legislature intended to allow for direct action in circuit court—in contravention of the broadly defined scope of the RPA—it could have expressly provided for such immediate judicial review." B & A Dev., 361 S.C. at 460 , 605 S.E.2d at 554 ; see also Buist v. Huggins, 367 S.C. 268, 276 , 625 S.E.2d 636, 640 (2006) (where a statute's language is plain, unambiguous, and conveys a clear meaning, the court has no right to impose another meaning).

2007Put simply, we agree with the Court of Appeals' observation that "[h]ad the *269 Legislature intended to allow for direct action in circuit court—in contravention of the broadly defined scope of the RPA—it could have expressly provided for such immediate judicial review." B & A Dev., 361 S.C. at 460 , 605 S.E.2d at 554 ; see also Buist v. Huggins, 367 S.C. 268, 276 , 625 S.E.2d 636, 640 (2006) (where a statute's language is plain, unambiguous, and conveys a clear meaning, the court has no right to impose another meaning).

11
Finnerty v. Cowengreen
ca2 · 1974 · cited in 1 South Carolina opinions naming this issue, 2000–2000
1 sentence

2000See, e.g., Finnerty v. Cowen, 508 F.2d 979 (2d Cir.1974); Martinez v. Richardson, 472 *39 F.2d 1121 (10th Cir.1973); Marsh v. County Sch.

11
Townsend v. Sainred
scotus · 1963 · cited in 1 South Carolina opinions naming this issue, 1998–1998
2 sentences

1998See Townsend v. Sain, 372 U.S. 293 , 83 S.Ct. 745 , 9 L.Ed.2d 770 (1963); Brown v. Allen, 344 U.S. 443 , 73 S.Ct. 397 , 97 L.Ed. 469 (1953); Young v. Ragen, 337 U.S. 235 , 69 S.Ct. 1073 , 93 L.Ed. 1333 (1949).

1998See Townsend v. Sain, 372 U.S. 293 , 83 S.Ct. 745 , 9 L.Ed.2d 770 (1963); Brown v. Allen, 344 U.S. 443 , 73 S.Ct. 397 , 97 L.Ed. 469 (1953); Young v. Ragen, 337 U.S. 235 , 69 S.Ct. 1073 , 93 L.Ed. 1333 (1949).

11
Matter of Estate of Ruckergreen
iowa · 1989 · cited in 1 South Carolina opinions naming this issue, 1997–1997
1 sentence

1997See, e.g., Rucker, 442 N.W.2d at 116 ; Schmidt, 338 N.W.2d at 256 ; Mulholland, 527 N.E.2d at 29 ; Longworth, 538 A.2d at 414 .

11
Boyle v. Erie Insurancegreen
pasuperct · 1995 · cited in 1 South Carolina opinions naming this issue, 1997–1997
2 sentences

1997Co., 441 Pa.Super. 103 , 656 A.2d 941, 943 (1995) (construing an exhaustion clause as a “threshold requirement and not a barrier to underinsured motorist insurance coverage”); Leal v. Northwestern Nat.

1997Co., 441 Pa.Super. 103 , 656 A.2d 941, 943 (1995) (construing an exhaustion clause as a “threshold requirement and not a barrier to underinsured motorist insurance coverage”); Leal v. Northwestern Nat.

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 (13)

CaseCitedYears
Brown v. James green
scctapp · 2010
2 sentences

2024Next, in Brown, this court noted "[an] exception to the exhaustion requirement is recognized when an agency has acted outside of its authority." 389 S.C. at 55 , 697 S.E.2d at 611 -12 (citing Responsible Econ.

2024Next, in Brown, this court noted "[an] exception to the exhaustion requirement is recognized when an agency has acted outside of its authority." 389 S.C. at 55 , 697 S.E.2d at 611 -12 (citing Responsible Econ.

12024–2024
Andrews Bearing Corp. v. Brady green
sc · 1973
2 sentences

2012Dep't of Revenue, 342 S.C. 34, 39 , 535 S.E.2d 642, 645 (2000) (finding that "the mere presence of a constitutional issue does not excuse the exhaustion requirement where there are other issues in controversy"); Law, 368 S.C. at 438 , 629 S.E.2d at 650 (stating that whether to require the plaintiff to exhaust administrative remedies is a matter within the sound discretion of the trial judge and will not be disturbed on appeal absent an abuse of discretion (citing Andrews Bearing Corp., 261 S.C. at 536 , 201 S.E.2d at 243 ; Tri-County Ice & Fuel Co. v. Palmetto Ice Co., 303 S.C. 237, 242 , 399

2012Dep't of Revenue, 342 S.C. 34, 39 , 535 S.E.2d 642, 645 (2000) (finding that "the mere presence of a constitutional issue does not excuse the exhaustion requirement where there are other issues in controversy"); Law, 368 S.C. at 438 , 629 S.E.2d at 650 (stating that whether to require the plaintiff to exhaust administrative remedies is a matter within the sound discretion of the trial judge and will not be disturbed on appeal absent an abuse of discretion (citing Andrews Bearing Corp., 261 S.C. at 536 , 201 S.E.2d at 243 ; Tri-County Ice & Fuel Co. v. Palmetto Ice Co., 303 S.C. 237, 242 , 399

12012–2012
Woodford v. Ngo red
scotus · 2006
2 sentences

2009Id.

2009Id.

12009–2009
B & a Development, Inc. v. Georgetown County neutral
scctapp · 2004
2 sentences

2007Put simply, we agree with the Court of Appeals' observation that "[h]ad the *269 Legislature intended to allow for direct action in circuit court—in contravention of the broadly defined scope of the RPA—it could have expressly provided for such immediate judicial review." B & A Dev., 361 S.C. at 460 , 605 S.E.2d at 554 ; see also Buist v. Huggins, 367 S.C. 268, 276 , 625 S.E.2d 636, 640 (2006) (where a statute's language is plain, unambiguous, and conveys a clear meaning, the court has no right to impose another meaning).

2007Put simply, we agree with the Court of Appeals' observation that "[h]ad the *269 Legislature intended to allow for direct action in circuit court—in contravention of the broadly defined scope of the RPA—it could have expressly provided for such immediate judicial review." B & A Dev., 361 S.C. at 460 , 605 S.E.2d at 554 ; see also Buist v. Huggins, 367 S.C. 268, 276 , 625 S.E.2d 636, 640 (2006) (where a statute's language is plain, unambiguous, and conveys a clear meaning, the court has no right to impose another meaning).

12007–2007
O'Sullivan v. Boerckel green
scotus · 1999
2 sentences

2002O’Sullivan, 526 U.S. at 848 , 119 S.Ct. at 1734 , 144 L.Ed.2d at 11 2 (emphasis added). *277 The Ninth Circuit addressed the issue that this Court is now facing in Swoopes v. Sublett, 196 F.3d 1008 (9th Cir.1999).

2002O’Sullivan, 526 U.S. at 848 , 119 S.Ct. at 1734 , 144 L.Ed.2d at 11 2 (emphasis added). *277 The Ninth Circuit addressed the issue that this Court is now facing in Swoopes v. Sublett, 196 F.3d 1008 (9th Cir.1999).

12002–2002
Samuel W. Swoopes v. Sam Sublett Grant Woods, Attorney General green
ca9 · 1999
1 sentence

2002O’Sullivan, 526 U.S. at 848 , 119 S.Ct. at 1734 , 144 L.Ed.2d at 11 2 (emphasis added). *277 The Ninth Circuit addressed the issue that this Court is now facing in Swoopes v. Sublett, 196 F.3d 1008 (9th Cir.1999).

12002–2002
Young v. Ragen green
scotus · 1949
2 sentences

1998See Townsend v. Sain, 372 U.S. 293 , 83 S.Ct. 745 , 9 L.Ed.2d 770 (1963); Brown v. Allen, 344 U.S. 443 , 73 S.Ct. 397 , 97 L.Ed. 469 (1953); Young v. Ragen, 337 U.S. 235 , 69 S.Ct. 1073 , 93 L.Ed. 1333 (1949).

1998See Townsend v. Sain, 372 U.S. 293 , 83 S.Ct. 745 , 9 L.Ed.2d 770 (1963); Brown v. Allen, 344 U.S. 443 , 73 S.Ct. 397 , 97 L.Ed. 469 (1953); Young v. Ragen, 337 U.S. 235 , 69 S.Ct. 1073 , 93 L.Ed. 1333 (1949).

11998–1998
Brown v. Allen green
scotus · 1953
2 sentences

1998See Townsend v. Sain, 372 U.S. 293 , 83 S.Ct. 745 , 9 L.Ed.2d 770 (1963); Brown v. Allen, 344 U.S. 443 , 73 S.Ct. 397 , 97 L.Ed. 469 (1953); Young v. Ragen, 337 U.S. 235 , 69 S.Ct. 1073 , 93 L.Ed. 1333 (1949).

1998See Townsend v. Sain, 372 U.S. 293 , 83 S.Ct. 745 , 9 L.Ed.2d 770 (1963); Brown v. Allen, 344 U.S. 443 , 73 S.Ct. 397 , 97 L.Ed. 469 (1953); Young v. Ragen, 337 U.S. 235 , 69 S.Ct. 1073 , 93 L.Ed. 1333 (1949).

11998–1998
Mulholland v. State Farm Mutual Automobile Insurance green
illappct · 1988
1 sentence

1997See, e.g., Rucker, 442 N.W.2d at 116 ; Schmidt, 338 N.W.2d at 256 ; Mulholland, 527 N.E.2d at 29 ; Longworth, 538 A.2d at 414 .

11997–1997
Schmidt v. Clothier red
minn · 1983
1 sentence

1997See, e.g., Rucker, 442 N.W.2d at 116 ; Schmidt, 338 N.W.2d at 256 ; Mulholland, 527 N.E.2d at 29 ; Longworth, 538 A.2d at 414 .

11997–1997
Longworth v. Van Houten green
njsuperctappdiv · 1988
1 sentence

1997See, e.g., Rucker, 442 N.W.2d at 116 ; Schmidt, 338 N.W.2d at 256 ; Mulholland, 527 N.E.2d at 29 ; Longworth, 538 A.2d at 414 .

11997–1997
Bennett v. South Carolina Department of Corrections green
sc · 1991
2 sentences

1996In Bennett v. South Carolina Dep’t of Corrections, 305 S.C. 310 , 408 S.E. (2d) 230 (1991) the supreme court found the exhaustion requirement did not bar the bringing of an action for statutory retaliatory discharge following the decision of the Grievance Committee.

1996In Bennett v. South Carolina Dep’t of Corrections, 305 S.C. 310 , 408 S.E. (2d) 230 (1991) the supreme court found the exhaustion requirement did not bar the bringing of an action for statutory retaliatory discharge following the decision of the Grievance Committee.

11996–1996
Porter v. North Carolina Department of Insurance green
ncctapp · 1979
1 sentence

1990This approach is consistent with that of our sister court in North Carolina as well as other jurisdictions. 5 In Potter v. North Carolina Department of Insurance, 40 N.C.

11990–1990

Where else courts name it

CA 418 (1897–2026) CT 286 (1979–2026) TX 203 (1973–2026) IL 189 (1963–2026) NY 151 (1974–2026) IN 98 (1979–2026) PA 93 (1954–2026) WA 71 (1984–2026) IA 70 (1972–2026) MD 61 (1980–2023) MA 52 (1976–2026) NJ 51 (1962–2024) WI 44 (1974–2026) FL 43 (1976–2025) MI 38 (1968–2026) AZ 37 (1963–2023) OH 36 (1975–2025) GA 36 (1980–2026) CO 36 (1974–2026) KS 36 (1974–2026) OR 35 (1974–2026) ID 29 (1978–2026) NV 28 (1992–2025) DC 27 (1985–2017) NM 27 (1966–2025) RI 27 (1966–2026) AK 27 (1981–2025) UT 24 (1992–2024) MT 24 (1981–2025) MO 23 (1957–2021) VT 21 (1986–2025) HI 20 (1987–2025) LA 19 (1989–2024) NC 18 (1991–2022) OK 18 (1977–2018) WY 17 (1982–2025) AL 16 (1980–2012) TN 16 (1995–2025) MN 15 (1981–2012) ME 15 (1984–2024) MS 14 (1963–2026) NE 14 (1998–2019) SD 13 (1975–2018) SC 12 (1990–2024) AR 11 (1996–2020) VA 11 (1982–2026) WV 9 (1989–2023) NH 6 (1989–2014) KY 5 (1981–2026) ND 5 (1997–2024) VI 2 (1988–1995) DE 2 (1975–2023)

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.

← Caselaw search · G Cite Topics · Brief Check