two-issue rule (South Carolina) · Go Syfert
← South Carolina issues

two-issue rule in South Carolina

74 South Carolina opinions name it 2 courts 1985–2026 13 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 (35)

CaseFollowedCited
Jones v. Lottgreen
sc · 2010 · cited in 57 South Carolina opinions naming this issue, 2010–2026
2 sentences

2026See Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010) ("Under the two issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become the law of the case."), abrogated on other grounds by Repko v. County of Georgetown, 424 S.C. 494 , 818 S.E.2d 743 (2018); Atl.

2026See Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010) ("Under the two issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become the law of the case."), abrogated on other grounds by Repko v. County of Georgetown, 424 S.C. 494 , 818 S.E.2d 743 (2018); Atl.

5757
Atlantic Coast Builders & Contractors, LLC v. Lewisgreen
sc · 2012 · cited in 10 South Carolina opinions naming this issue, 2015–2026
2 sentences

2024Coast Builders & Contractors, LLC v. Lewis, 398 S.C. 323, 328 , 730 S.E.2d 282, 284 (2012) ("Under the two issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become law of the case." (quoting Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010), abrogated on other grounds by Repko v. County Of Georgetown, 424 S.C. 494 , 818 S.E.2d 743 (2018))); Shirley's Iron Works, 403 S.C. at 573 , 743 S.E.2d at 785 ("An unappealed ruling is the law of the case and requires affirma

2024Coast Builders & Contractors, LLC v. Lewis, 398 S.C. 323, 328 , 730 S.E.2d 282, 284 (2012) ("Under the two issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become law of the case." (quoting Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010), abrogated on other grounds by Repko v. County Of Georgetown, 424 S.C. 494 , 818 S.E.2d 743 (2018))); Shirley's Iron Works, 403 S.C. at 573 , 743 S.E.2d at 785 ("An unappealed ruling is the law of the case and requires affirma

910
First Union Nat. Bank of SC v. Sodengreen
scctapp · 1998 · cited in 8 South Carolina opinions naming this issue, 2010–2018
2 sentences

2018See Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010) ("Every ground of appeal ought to be so distinctly stated that the reviewing court may at once see the point which it is called upon to decide without having to 'grope in the dark' to ascertain the precise point at issue." (quoting Forest Dunes Assocs. v. Club Carib, Inc., 301 S.C. 87, 89 , 390 S.E.2d 368, 370 (Ct. App. 1990))); First Union Nat'l Bank of S.C. v. Soden, 333 S.C. 554, 566 , 511 S.E.2d 372, 378 (Ct. App. 1998) (explaining an "unchallenged ruling, right or wrong, is the law of the case and requires affirmance"); Jon

2018See Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010) ("Every ground of appeal ought to be so distinctly stated that the reviewing court may at once see the point which it is called upon to decide without having to 'grope in the dark' to ascertain the precise point at issue." (quoting Forest Dunes Assocs. v. Club Carib, Inc., 301 S.C. 87, 89 , 390 S.E.2d 368, 370 (Ct. App. 1990))); First Union Nat'l Bank of S.C. v. Soden, 333 S.C. 554, 566 , 511 S.E.2d 372, 378 (Ct. App. 1998) (explaining an "unchallenged ruling, right or wrong, is the law of the case and requires affirmance"); Jon

88
Repko v. Cnty. of Georgetowngreen
sc · 2018 · cited in 11 South Carolina opinions naming this issue, 2019–2026
2 sentences

2026See Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010) ("Under the two issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become the law of the case."), abrogated on other grounds by Repko v. County of Georgetown, 424 S.C. 494 , 818 S.E.2d 743 (2018); Atl.

2026See Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010) ("Under the two issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become the law of the case."), abrogated on other grounds by Repko v. County of Georgetown, 424 S.C. 494 , 818 S.E.2d 743 (2018); Atl.

611
Anderson v. Shortgreen
sc · 1996 · cited in 6 South Carolina opinions naming this issue, 2010–2018
2 sentences

2018See Jones v. Lott , 387 S.C. 339 , 346, 692 S.E.2d 900 , 903 (2010) ("Under the [two-issue] rule, [when] a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become the law of the case."); id. , 692 S.E.2d at 903-04 (noting that the two-issue rule can be applied to situations not involving a jury); Anderson v. Short , 323 S.C. 522 , 525, 476 S.E.2d 475 , 477 (1996) (affirming the trial court's decision because the plaintiff did not appeal all grounds for the decision); see also *365 Atl.

2018See Jones v. Lott , 387 S.C. 339 , 346, 692 S.E.2d 900 , 903 (2010) ("Under the [two-issue] rule, [when] a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become the law of the case."); id. , 692 S.E.2d at 903-04 (noting that the two-issue rule can be applied to situations not involving a jury); Anderson v. Short , 323 S.C. 522 , 525, 476 S.E.2d 475 , 477 (1996) (affirming the trial court's decision because the plaintiff did not appeal all grounds for the decision); see also *365 Atl.

56
Cole v. Rautgreen
sc · 2008 · cited in 4 South Carolina opinions naming this issue, 2010–2025
2 sentences

2025Bank of S.C., 286 S.C. 272, 282 , 333 S.E.2d 67, 73 (Ct. App. 1985) ("[W]here a jury returns a general verdict in a case involving two or more issues or defenses and its verdict is supported as to at least one issue or defense, the verdict will not be reversed."); Cole v. Raut, 378 S.C. 398, 407 , 663 S.E.2d 30, 34 (2008) ("The application of the two-issue rule is separate and distinct from a prejudicial error inquiry, and operates to uphold a jury verdict that is sustained by the facts of the case."); id. ("The rule is consistent with the established notion that the appellate courts in this S

2025Bank of S.C., 286 S.C. 272, 282 , 333 S.E.2d 67, 73 (Ct. App. 1985) ("[W]here a jury returns a general verdict in a case involving two or more issues or defenses and its verdict is supported as to at least one issue or defense, the verdict will not be reversed."); Cole v. Raut, 378 S.C. 398, 407 , 663 S.E.2d 30, 34 (2008) ("The application of the two-issue rule is separate and distinct from a prejudicial error inquiry, and operates to uphold a jury verdict that is sustained by the facts of the case."); id. ("The rule is consistent with the established notion that the appellate courts in this S

44
Anderson Ex Rel. Estate of Anderson v. Westgreen
sc · 1978 · cited in 6 South Carolina opinions naming this issue, 1985–2008
2 sentences

1988Cf. Anderson v. West, 270 S. C. 184, 241 S. E. (2d) 551 (1978) (even if the trial judge erred in submitting an issue to the jury, the two-issue rule requires affirmance where there is sufficient evidence under one theory to submit the case).

1985It cites Anderson v. West, 270 S. C. 184, 241 S. E. (2d) 551 (1978) in which we held that even if there were error in allowing an issue to go to the jury, application of the two issue rule requires affirmance where there is sufficient evidence under one theory to submit the case to the jury.

36
Anderson v. South Carolina Department of Highways & Public Transportationgreen
sc · 1996 · cited in 3 South Carolina opinions naming this issue, 2004–2023
2 sentences

2023Transp., 322 S.C. 417, 419-20 , 472 S.E.2d 253, 254-55 (1996) (explaining the two-issue rule); id. at 420 , 472 S.E.2d at 254 ("[W]hen a jury's general verdict is supportable by more than one cause of action submitted to it, the appellate court will affirm unless the appellant appeals all causes of action.").

2023Transp., 322 S.C. 417, 419-20 , 472 S.E.2d 253, 254-55 (1996) (explaining the two-issue rule); id. at 420 , 472 S.E.2d at 254 ("[W]hen a jury's general verdict is supportable by more than one cause of action submitted to it, the appellate court will affirm unless the appellant appeals all causes of action.").

33
Gold Kist, Inc. v. Citizens & Southern National Bank Ex Rel. Estate of Lanhamgreen
scctapp · 1985 · cited in 2 South Carolina opinions naming this issue, 2008–2025
2 sentences

2025Bank of S.C., 286 S.C. 272, 282 , 333 S.E.2d 67, 73 (Ct. App. 1985) ("[W]here a jury returns a general verdict in a case involving two or more issues or defenses and its verdict is supported as to at least one issue or defense, the verdict will not be reversed."); Cole v. Raut, 378 S.C. 398, 407 , 663 S.E.2d 30, 34 (2008) ("The application of the two-issue rule is separate and distinct from a prejudicial error inquiry, and operates to uphold a jury verdict that is sustained by the facts of the case."); id. ("The rule is consistent with the established notion that the appellate courts in this S

2025Bank of S.C., 286 S.C. 272, 282 , 333 S.E.2d 67, 73 (Ct. App. 1985) ("[W]here a jury returns a general verdict in a case involving two or more issues or defenses and its verdict is supported as to at least one issue or defense, the verdict will not be reversed."); Cole v. Raut, 378 S.C. 398, 407 , 663 S.E.2d 30, 34 (2008) ("The application of the two-issue rule is separate and distinct from a prejudicial error inquiry, and operates to uphold a jury verdict that is sustained by the facts of the case."); id. ("The rule is consistent with the established notion that the appellate courts in this S

22
Shirley's Iron Works, Inc. v. City of Uniongreen
sc · 2013 · cited in 2 South Carolina opinions naming this issue, 2013–2024
2 sentences

2024Coast Builders & Contractors, LLC v. Lewis, 398 S.C. 323, 328 , 730 S.E.2d 282, 284 (2012) ("Under the two issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become law of the case." (quoting Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010), abrogated on other grounds by Repko v. County Of Georgetown, 424 S.C. 494 , 818 S.E.2d 743 (2018))); Shirley's Iron Works, 403 S.C. at 573 , 743 S.E.2d at 785 ("An unappealed ruling is the law of the case and requires affirma

2024Coast Builders & Contractors, LLC v. Lewis, 398 S.C. 323, 328 , 730 S.E.2d 282, 284 (2012) ("Under the two issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become law of the case." (quoting Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010), abrogated on other grounds by Repko v. County Of Georgetown, 424 S.C. 494 , 818 S.E.2d 743 (2018))); Shirley's Iron Works, 403 S.C. at 573 , 743 S.E.2d at 785 ("An unappealed ruling is the law of the case and requires affirma

22
Dropkin v. Beachwalk Villas Condominium Ass'ngreen
scctapp · 2007 · cited in 2 South Carolina opinions naming this issue, 2008–2014
2 sentences

2014Ass'n, Inc., 373 S.C. 360, 365 , 644 S.E.2d 808, 810 (Ct. App. 2007) (holding under the two-issue rule, when a jury verdict involves two or more issues and its verdict is supported as to at least one issue, the verdict will not be reversed on appeal). 4.

2014Ass'n, Inc., 373 S.C. 360, 365 , 644 S.E.2d 808, 810 (Ct. App. 2007) (holding under the two-issue rule, when a jury verdict involves two or more issues and its verdict is supported as to at least one issue, the verdict will not be reversed on appeal). 4.

22
Sierra v. Skeltongreen
scctapp · 1992 · cited in 2 South Carolina opinions naming this issue, 2008–2010
2 sentences

2010We affirm pursuant to Rule 220, SCACR, and the following authorities: Cole v. Raut , 378 S.C. 398, 406-07 , 663 S.E.2d 30, 34 (2008) (stating under the two-issue rule, when a jury returns a general verdict in a case involving two or more issues or defenses, and the verdict is supported as to at least one issue or defense that has been presented to the jury free from error, the verdict will not be reversed); Jones v. Lott , 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010) ("Under the two issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appe

2010We affirm pursuant to Rule 220, SCACR, and the following authorities: Cole v. Raut , 378 S.C. 398, 406-07 , 663 S.E.2d 30, 34 (2008) (stating under the two-issue rule, when a jury returns a general verdict in a case involving two or more issues or defenses, and the verdict is supported as to at least one issue or defense that has been presented to the jury free from error, the verdict will not be reversed); Jones v. Lott , 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010) ("Under the two issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appe

12
Bryant v. Waste Management, Inc.green
scctapp · 2000 · cited in 2 South Carolina opinions naming this issue, 2007–2008
2 sentences

2008See also Dropkin v. Beachwalk Villas Condominium, Assn., 373 S.C. 360 , 644 S.E.2d 808 (Ct.App.2007) (affirming a general defense verdict under the two-issue rule where plaintiff alleged error in the trial court’s denial of a directed verdict on the issue of negligence, but where the record contained evidence supporting a defense verdict on the issue of proximate cause); Bryant v. Waste Management, Inc., 342 S.C. 159 , 536 S.E.2d 380 (Ct.App.2000) (applying the two-issue rule to determine that an erroneous instruction on negligence per se was not prejudicial to the defendant where there existe

2008See also Dropkin v. Beachwalk Villas Condominium, Assn., 373 S.C. 360 , 644 S.E.2d 808 (Ct.App.2007) (affirming a general defense verdict under the two-issue rule where plaintiff alleged error in the trial court’s denial of a directed verdict on the issue of negligence, but where the record contained evidence supporting a defense verdict on the issue of proximate cause); Bryant v. Waste Management, Inc., 342 S.C. 159 , 536 S.E.2d 380 (Ct.App.2000) (applying the two-issue rule to determine that an erroneous instruction on negligence per se was not prejudicial to the defendant where there existe

12
Graves v. Horry-Georgetown Technical Collegegreen
scctapp · 2010 · cited in 1 South Carolina opinions naming this issue, 2024–2024
2 sentences

2024Coll., 391 S.C. 1, 8 , 704 S.E.2d 350, 354 (Ct. App. 2010) ("Under the two-issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become the law of the case." (quoting Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010), abrogated on other grounds by Repko v. County. of Georgetown, 424 S.C. 494 , 818 S.E.2d 743 (2018))).

2024Coll., 391 S.C. 1, 8 , 704 S.E.2d 350, 354 (Ct. App. 2010) ("Under the two-issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become the law of the case." (quoting Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010), abrogated on other grounds by Repko v. County. of Georgetown, 424 S.C. 494 , 818 S.E.2d 743 (2018))).

11
Vinson v. Jacksongreen
sc · 1997 · cited in 1 South Carolina opinions naming this issue, 2023–2023
2 sentences

2023See Vinson v. Jackson, 327 S.C. 290, 293 , 491 S.E.2d 249, 250 (1997) ("A jury verdict should be upheld when it is possible to do so and carry into effect the jury's clear intention." (quoting Johnson v. Parker, 279 S.C. 132, 135 , 303 S.E.2d 95, 97 (1983))); Anderson v. S.C.

2023See Vinson v. Jackson, 327 S.C. 290, 293 , 491 S.E.2d 249, 250 (1997) ("A jury verdict should be upheld when it is possible to do so and carry into effect the jury's clear intention." (quoting Johnson v. Parker, 279 S.C. 132, 135 , 303 S.E.2d 95, 97 (1983))); Anderson v. S.C.

11
Johnson v. Parkergreen
sc · 1983 · cited in 1 South Carolina opinions naming this issue, 2023–2023
2 sentences

2023See Vinson v. Jackson, 327 S.C. 290, 293 , 491 S.E.2d 249, 250 (1997) ("A jury verdict should be upheld when it is possible to do so and carry into effect the jury's clear intention." (quoting Johnson v. Parker, 279 S.C. 132, 135 , 303 S.E.2d 95, 97 (1983))); Anderson v. S.C.

2023See Vinson v. Jackson, 327 S.C. 290, 293 , 491 S.E.2d 249, 250 (1997) ("A jury verdict should be upheld when it is possible to do so and carry into effect the jury's clear intention." (quoting Johnson v. Parker, 279 S.C. 132, 135 , 303 S.E.2d 95, 97 (1983))); Anderson v. S.C.

11
Ulmer v. Ulmergreen
sc · 2006 · cited in 1 South Carolina opinions naming this issue, 2022–2022
2 sentences

2022Further, because Agape has preserved only one ground for the denial of the directed verdict for appeal (agency)—but not the grounds of alter-ego, joint-venture, or amalgamation of interests—these grounds for liability, and the general verdict that resulted from their presentation to the jury, are the law of the case and unassailable on appeal due to the two-issue rule.2 See Ulmer v. Ulmer, 369 S.C. 486, 490 , 632 S.E.2d 858, 861 (2006) (finding, as a general rule, an unchallenged ruling, right or wrong, is the law of the case); Todd v. S.C.

2022Further, because Agape has preserved only one ground for the denial of the directed verdict for appeal (agency)—but not the grounds of alter-ego, joint-venture, or amalgamation of interests—these grounds for liability, and the general verdict that resulted from their presentation to the jury, are the law of the case and unassailable on appeal due to the two-issue rule.2 See Ulmer v. Ulmer, 369 S.C. 486, 490 , 632 S.E.2d 858, 861 (2006) (finding, as a general rule, an unchallenged ruling, right or wrong, is the law of the case); Todd v. S.C.

11
Folkens v. Huntgreen
scctapp · 1986 · cited in 1 South Carolina opinions naming this issue, 2019–2019
2 sentences

2019Dep't of Revenue, 337 S.C. 601, 605 , 524 S.E.2d 626, 628 (1999) ("Failure to appeal an alternative ground of the judgment will result in affirmance."); Folkens v. Hunt, 290 S.C. 194, 205 , 348 S.E.2d 839, 846 (Ct. App. 1986) ("An alternative ruling of a lower court that is not excepted to constitutes a basis for affirming the lower court and is not reviewable on appeal.").

2019Dep't of Revenue, 337 S.C. 601, 605 , 524 S.E.2d 626, 628 (1999) ("Failure to appeal an alternative ground of the judgment will result in affirmance."); Folkens v. Hunt, 290 S.C. 194, 205 , 348 S.E.2d 839, 846 (Ct. App. 1986) ("An alternative ruling of a lower court that is not excepted to constitutes a basis for affirming the lower court and is not reviewable on appeal.").

11
Walbeck v. I'On Co.green
scctapp · 2018 · cited in 1 South Carolina opinions naming this issue, 2019–2019
2 sentences

2019Coast Builders & Contractors, LLC v. Lewis, 398 S.C. 323, 328 , 730 S.E.2d 282, 284 (2012) ("Under the two issue rule, [when] a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become law of the case." (quoting Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010))); Walbeck v. I'On Co., 426 S.C. 494, 526 , 827 S.E.2d 348, 364 (Ct. App. 2019) (recognizing the two issue rule can be applied in situations not involving a jury).

2019Coast Builders & Contractors, LLC v. Lewis, 398 S.C. 323, 328 , 730 S.E.2d 282, 284 (2012) ("Under the two issue rule, [when] a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become law of the case." (quoting Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010))); Walbeck v. I'On Co., 426 S.C. 494, 526 , 827 S.E.2d 348, 364 (Ct. App. 2019) (recognizing the two issue rule can be applied in situations not involving a jury).

11
Mibbs, Inc. v. South Carolina Department of Revenuegreen
sc · 1999 · cited in 1 South Carolina opinions naming this issue, 2019–2019
2 sentences

2019Dep't of Revenue, 337 S.C. 601, 605 , 524 S.E.2d 626, 628 (1999) ("Failure to appeal an alternative ground of the judgment will result in affirmance."); Folkens v. Hunt, 290 S.C. 194, 205 , 348 S.E.2d 839, 846 (Ct. App. 1986) ("An alternative ruling of a lower court that is not excepted to constitutes a basis for affirming the lower court and is not reviewable on appeal.").

2019Dep't of Revenue, 337 S.C. 601, 605 , 524 S.E.2d 626, 628 (1999) ("Failure to appeal an alternative ground of the judgment will result in affirmance."); Folkens v. Hunt, 290 S.C. 194, 205 , 348 S.E.2d 839, 846 (Ct. App. 1986) ("An alternative ruling of a lower court that is not excepted to constitutes a basis for affirming the lower court and is not reviewable on appeal.").

11
McClurg v. Deatongreen
sc · 2011 · cited in 1 South Carolina opinions naming this issue, 2019–2019
2 sentences

2019As to the County's argument on the statute of limitations, we find because the County failed to challenge the trial court's ruling the statute of limitations was tolled until 2011, this ruling is the law of the case: Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010) ("Under the two issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become the law of the case."), abrogated on other grounds by Repko v. Cty. of Georgetown, 424 S.C. 494 , 818 S.E.2d 743 (2018); McClur

2019As to the County's argument on the statute of limitations, we find because the County failed to challenge the trial court's ruling the statute of limitations was tolled until 2011, this ruling is the law of the case: Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010) ("Under the two issue rule, where a decision is based on more than one ground, the appellate court will affirm unless the appellant appeals all grounds because the unappealed ground will become the law of the case."), abrogated on other grounds by Repko v. Cty. of Georgetown, 424 S.C. 494 , 818 S.E.2d 743 (2018); McClur

11
Smalls v. Stategreen
sc · 2018 · cited in 1 South Carolina opinions naming this issue, 2018–2018
2 sentences

2018See, e.g. , Jones v. State , 382 S.C. 589 , 594, 677 S.E.2d 20 , 22 (2009) abrogated on other grounds by Smalls v. State , 422 S.C. 174 , 810 S.E.2d 836 (2018) (evaluating the merits of the State's appeal, despite the PCR judge's dismissal of the State's motion for reconsideration for failure to comply with Rule 59(g), SCRCP ).

2018See, e.g. , Jones v. State , 382 S.C. 589 , 594, 677 S.E.2d 20 , 22 (2009) abrogated on other grounds by Smalls v. State , 422 S.C. 174 , 810 S.E.2d 836 (2018) (evaluating the merits of the State's appeal, despite the PCR judge's dismissal of the State's motion for reconsideration for failure to comply with Rule 59(g), SCRCP ).

11
Forest Dunes Associates v. Club Carib, Inc.green
scctapp · 1990 · cited in 1 South Carolina opinions naming this issue, 2018–2018
2 sentences

2018See Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010) ("Every ground of appeal ought to be so distinctly stated that the reviewing court may at once see the point which it is called upon to decide without having to 'grope in the dark' to ascertain the precise point at issue." (quoting Forest Dunes Assocs. v. Club Carib, Inc., 301 S.C. 87, 89 , 390 S.E.2d 368, 370 (Ct. App. 1990))); First Union Nat'l Bank of S.C. v. Soden, 333 S.C. 554, 566 , 511 S.E.2d 372, 378 (Ct. App. 1998) (explaining an "unchallenged ruling, right or wrong, is the law of the case and requires affirmance"); Jon

2018See Jones v. Lott, 387 S.C. 339, 346 , 692 S.E.2d 900, 903 (2010) ("Every ground of appeal ought to be so distinctly stated that the reviewing court may at once see the point which it is called upon to decide without having to 'grope in the dark' to ascertain the precise point at issue." (quoting Forest Dunes Assocs. v. Club Carib, Inc., 301 S.C. 87, 89 , 390 S.E.2d 368, 370 (Ct. App. 1990))); First Union Nat'l Bank of S.C. v. Soden, 333 S.C. 554, 566 , 511 S.E.2d 372, 378 (Ct. App. 1998) (explaining an "unchallenged ruling, right or wrong, is the law of the case and requires affirmance"); Jon

11
Jones v. Stategreen
sc · 2009 · cited in 1 South Carolina opinions naming this issue, 2018–2018
2 sentences

2018See, e.g. , Jones v. State , 382 S.C. 589 , 594, 677 S.E.2d 20 , 22 (2009) abrogated on other grounds by Smalls v. State , 422 S.C. 174 , 810 S.E.2d 836 (2018) (evaluating the merits of the State's appeal, despite the PCR judge's dismissal of the State's motion for reconsideration for failure to comply with Rule 59(g), SCRCP ).

2018See, e.g. , Jones v. State , 382 S.C. 589 , 594, 677 S.E.2d 20 , 22 (2009) abrogated on other grounds by Smalls v. State , 422 S.C. 174 , 810 S.E.2d 836 (2018) (evaluating the merits of the State's appeal, despite the PCR judge's dismissal of the State's motion for reconsideration for failure to comply with Rule 59(g), SCRCP ).

11
North American Rescue Products, Inc. v. Richardsongreen
sc · 2015 · cited in 1 South Carolina opinions naming this issue, 2016–2016
2 sentences

2016Rescue Prods., Inc. v. Richardson, 411 S.C. 371, 379 , 769 S.E.2d 237, 241 (2015) (providing that "agreements to agree in the future have no legal effect" and are void for indefiniteness).1 AFFIRMED.2 LOCKEMY, C.J., and WILLIAMS and MCDONALD, JJ., concur. 1 We find the two-issue rule is inapplicable to this appeal.

2016Rescue Prods., Inc. v. Richardson, 411 S.C. 371, 379 , 769 S.E.2d 237, 241 (2015) (providing that "agreements to agree in the future have no legal effect" and are void for indefiniteness).1 AFFIRMED.2 LOCKEMY, C.J., and WILLIAMS and MCDONALD, JJ., concur. 1 We find the two-issue rule is inapplicable to this appeal.

11
Weatherford v. Pricegreen
scctapp · 2000 · cited in 1 South Carolina opinions naming this issue, 2015–2015
2 sentences

2015See Cole v. Raut, 378 S.C. 398, 406-07 , 663 S.E.2d 30, 34 (2008) ("Under the two-issue rule, when a jury returns a general verdict in a case involving two or more issues or defenses, and the verdict is supported as to at least one issue or defense that has been presented to the jury free from error, the verdict will not be reversed."); id. at 407 ; 663 S.E.2d at 34 ("The application of the two-issue rule is separate and distinct from a prejudicial error inquiry, and operates to uphold a jury verdict that is sustained by the facts of the case."); Consignment Sales, LLC v. Tucker Oil Co., 391 S

2015See Cole v. Raut, 378 S.C. 398, 406-07 , 663 S.E.2d 30, 34 (2008) ("Under the two-issue rule, when a jury returns a general verdict in a case involving two or more issues or defenses, and the verdict is supported as to at least one issue or defense that has been presented to the jury free from error, the verdict will not be reversed."); id. at 407 ; 663 S.E.2d at 34 ("The application of the two-issue rule is separate and distinct from a prejudicial error inquiry, and operates to uphold a jury verdict that is sustained by the facts of the case."); Consignment Sales, LLC v. Tucker Oil Co., 391 S

11
Consignment Sales, LLC v. Tucker Oil Co.green
scctapp · 2010 · cited in 1 South Carolina opinions naming this issue, 2015–2015
2 sentences

2015See Cole v. Raut, 378 S.C. 398, 406-07 , 663 S.E.2d 30, 34 (2008) ("Under the two-issue rule, when a jury returns a general verdict in a case involving two or more issues or defenses, and the verdict is supported as to at least one issue or defense that has been presented to the jury free from error, the verdict will not be reversed."); id. at 407 ; 663 S.E.2d at 34 ("The application of the two-issue rule is separate and distinct from a prejudicial error inquiry, and operates to uphold a jury verdict that is sustained by the facts of the case."); Consignment Sales, LLC v. Tucker Oil Co., 391 S

2015See Cole v. Raut, 378 S.C. 398, 406-07 , 663 S.E.2d 30, 34 (2008) ("Under the two-issue rule, when a jury returns a general verdict in a case involving two or more issues or defenses, and the verdict is supported as to at least one issue or defense that has been presented to the jury free from error, the verdict will not be reversed."); id. at 407 ; 663 S.E.2d at 34 ("The application of the two-issue rule is separate and distinct from a prejudicial error inquiry, and operates to uphold a jury verdict that is sustained by the facts of the case."); Consignment Sales, LLC v. Tucker Oil Co., 391 S

11
Townes Associates, Ltd. v. City of Greenvillegreen
sc · 1976 · cited in 1 South Carolina opinions naming this issue, 2015–2015
2 sentences

2015See Cole v. Raut, 378 S.C. 398, 406-07 , 663 S.E.2d 30, 34 (2008) ("Under the two-issue rule, when a jury returns a general verdict in a case involving two or more issues or defenses, and the verdict is supported as to at least one issue or defense that has been presented to the jury free from error, the verdict will not be reversed."); id. at 407 ; 663 S.E.2d at 34 ("The application of the two-issue rule is separate and distinct from a prejudicial error inquiry, and operates to uphold a jury verdict that is sustained by the facts of the case."); Consignment Sales, LLC v. Tucker Oil Co., 391 S

2015See Cole v. Raut, 378 S.C. 398, 406-07 , 663 S.E.2d 30, 34 (2008) ("Under the two-issue rule, when a jury returns a general verdict in a case involving two or more issues or defenses, and the verdict is supported as to at least one issue or defense that has been presented to the jury free from error, the verdict will not be reversed."); id. at 407 ; 663 S.E.2d at 34 ("The application of the two-issue rule is separate and distinct from a prejudicial error inquiry, and operates to uphold a jury verdict that is sustained by the facts of the case."); Consignment Sales, LLC v. Tucker Oil Co., 391 S

11
South Carolina Tax Commission v. Gaston Copper Recycling Corp.green
sc · 1994 · cited in 1 South Carolina opinions naming this issue, 2014–2014
11
Smoak Ex Rel. Estate of Hudson v. Liebherr-America, Inc.green
sc · 1984 · cited in 1 South Carolina opinions naming this issue, 2012–2012
11
Gibson v. Stategreen
sc · 1998 · cited in 1 South Carolina opinions naming this issue, 2011–2011
11
Simpson v. Stategreen
sc · 1998 · cited in 1 South Carolina opinions naming this issue, 2011–2011
11
State v. Gallowaygreen
scctapp · 1991 · cited in 1 South Carolina opinions naming this issue, 2011–2011
11
State v. Hicksgreen
sc · 2010 · cited in 1 South Carolina opinions naming this issue, 2011–2011
11
Harry L. Hussman Refrigerator & Supply Co. v. Cash & Carry Grocer, Inc.green
sc · 1926 · cited in 1 South Carolina opinions naming this issue, 2008–2008
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 (6)

CaseCitedYears
Todd v. South Carolina Farm Bureau Mutual Insurance green
sc · 1985
2 sentences

2022Co., 287 S.C. 190, 193 , 336 S.E.2d 472 , 473–74 (1985) (finding when the general verdict of a jury is supportable under more than one cause of action submitted to it, under the two-issue rule, the appellate court will affirm unless appellant appeals all causes of action).

2022Co., 287 S.C. 190, 193 , 336 S.E.2d 472 , 473–74 (1985) (finding when the general verdict of a jury is supportable under more than one cause of action submitted to it, under the two-issue rule, the appellate court will affirm unless appellant appeals all causes of action).

12022–2022
Gallagher Ex Rel. Estate of Evert v. Evert green
scctapp · 2002
2 sentences

2018CompTrust's timeliness argument was answered by Gallagher v. Evert , 353 S.C. 59 , 63, 577 S.E.2d 217 , 219 (Ct. App. 2002) ("There is no indication that the failure to transmit a copy of the [ Rule 59(e), SCRCP, motion] to the circuit court affects the tolling provision of Rule 203(b)(1), SCACR.

2018CompTrust's timeliness argument was answered by Gallagher v. Evert , 353 S.C. 59 , 63, 577 S.E.2d 217 , 219 (Ct. App. 2002) ("There is no indication that the failure to transmit a copy of the [ Rule 59(e), SCRCP, motion] to the circuit court affects the tolling provision of Rule 203(b)(1), SCACR.

12018–2018
Cole Ex Rel. Estate of Cole v. Raut neutral
scctapp · 2005
12008–2008
Gasque v. Heublein, Inc. green
scctapp · 1984
11985–1985
Mylin v. Allen-White Pontiac, Inc. green
scctapp · 1984
11985–1985
Skipper v. Hartley neutral
sc · 1963
11985–1985

Statutes the citing opinions construe

SC § S.C. Code Ann. § 15-78-60 (4) SC § S.C. Code Ann. § 39-5-10 (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

SC 74 (1985–2026) OH 72 (1930–2025) FL 50 (1980–2024) IL 17 (2009–2025)

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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