legitimate claim in South Carolina

2026Protected liberty interests "may arise from two sources[:] the Due Process Clause itself and the laws of the States."'" (alteration in original) (quoting Thompson, 490 U.S. at 460 )), aff'd as modified, 439 S.C. at 167, 886 S.E.2d at 672 (2023); id. at 119, 862 S.E.2d at 270 ("In order to establish a state-created liberty interest, a regulation must 'contain "explicitly mandatory language," i.e., specific directives to the decisionmaker that if the regulations' substantive predicates are present, a particular outcome must follow.'" 1 We address Melton's four issues on appeal together. (quoting

2026Protected liberty interests "may arise from two sources[:] the Due Process Clause itself and the laws of the States."'" (alteration in original) (quoting Thompson, 490 U.S. at 460 )), aff'd as modified, 439 S.C. at 167, 886 S.E.2d at 672 (2023); id. at 119, 862 S.E.2d at 270 ("In order to establish a state-created liberty interest, a regulation must 'contain "explicitly mandatory language," i.e., specific directives to the decisionmaker that if the regulations' substantive predicates are present, a particular outcome must follow.'" 1 We address Melton's four issues on appeal together. (quoting

2025Co., 338 S.C. 131, 134 , 526 S.E.2d 218, 219 (2000) (reaffirming that a bad faith claim for "refusal to pay benefits does not extend to third parties who are not named insureds"); Mixson, Inc. v. American Loyalty Ins., 349 S.C. 394, 400 , 562 S.E.2d 659, 662 (2002) (expanding a bad faith claim to include not just nonpayment of a legitimate claim but how that claim was processed (citing Tadlock Painting Co v. Maryland Cas.

2025Co., 338 S.C. 131, 134 , 526 S.E.2d 218, 219 (2000) (reaffirming that a bad faith claim for "refusal to pay benefits does not extend to third parties who are not named insureds"); Mixson, Inc. v. American Loyalty Ins., 349 S.C. 394, 400 , 562 S.E.2d 659, 662 (2002) (expanding a bad faith claim to include not just nonpayment of a legitimate claim but how that claim was processed (citing Tadlock Painting Co v. Maryland Cas.

2025Co., 338 S.C. 131, 134 , 526 S.E.2d 218, 219 (2000) (reaffirming that a bad faith claim for "refusal to pay benefits does not extend to third parties who are not named insureds"); Mixson, Inc. v. American Loyalty Ins., 349 S.C. 394, 400 , 562 S.E.2d 659, 662 (2002) (expanding a bad faith claim to include not just nonpayment of a legitimate claim but how that claim was processed (citing Tadlock Painting Co v. Maryland Cas.

2025Co., 338 S.C. 131, 134 , 526 S.E.2d 218, 219 (2000) (reaffirming that a bad faith claim for "refusal to pay benefits does not extend to third parties who are not named insureds"); Mixson, Inc. v. American Loyalty Ins., 349 S.C. 394, 400 , 562 S.E.2d 659, 662 (2002) (expanding a bad faith claim to include not just nonpayment of a legitimate claim but how that claim was processed (citing Tadlock Painting Co v. Maryland Cas.

2022Comm'n, 389 S.C. 380, 392 , 699 S.E.2d 146, 153 (2010) (observing an interest protected by due process arises when there is a legitimate claim of entitlement that is created and defined by independent sources and not just by a "unilateral expectation" (citation omitted)).

2022Comm'n, 389 S.C. 380, 392 , 699 S.E.2d 146, 153 (2010) (observing an interest protected by due process arises when there is a legitimate claim of entitlement that is created and defined by independent sources and not just by a "unilateral expectation" (citation omitted)).

2021Protected liberty interests 'may arise from two sources[:] the Due Process Clause itself and the laws of the States.'" Id. at 460 (quoting Hewitt v. Helms, 459 U.S. 460, 466 (1983)).

2018Dep't of Corr., 355 S.C. 437, 445 , 586 S.E.2d 124, 128 (2003) (finding no state-created liberty interest in inmate participation in sex offender treatment programs promulgated by SCDC).

2018Dep't of Corr., 355 S.C. 437, 445 , 586 S.E.2d 124, 128 (2003) (finding no state-created liberty interest in inmate participation in sex offender treatment programs promulgated by SCDC).

2000He must, instead, have a legitimate claim of entitlement to it.” A clear entitlement exists in a permit when “the discretion of the issuing agency is so narrowly circumscribed that approval of a proper application is virtually assured.” Villager Pond, Inc., v. Town of Darien, 56 F.3d 375, 378 (2d Cir.1995) (citing RRI Realty Corp. v. Incorporated Village of Southampton, 870 F.2d 911, 918 (2d Cir.1989)).

2000He must, instead, have a legitimate claim of entitlement to it.” A clear entitlement exists in a permit when “the discretion of the issuing agency is so narrowly circumscribed that approval of a proper application is virtually assured.” Villager Pond, Inc., v. Town of Darien, 56 F.3d 375, 378 (2d Cir.1995) (citing RRI Realty Corp. v. Incorporated Village of Southampton, 870 F.2d 911, 918 (2d Cir.1989)).