The latest, from the Attorneys Who Know

Manner v. Purpose: How the South Carolina Supreme Court Declined to Extend the Reach of the Implied Covenant of Good Faith and Fair Dealing

BY Kelsey Brudvig

The South Carolina Supreme Court has clarified the scope of the covenant of good faith and fair dealing implied in every contract.  In Road, LLC v. Beaufort County, Op. No. 28204 (May 15, 2024), the Court held that a party’s...

The South Carolina Supreme Court has clarified the scope of the covenant of good faith and fair dealing implied in every contract.  In Road, LLC v. Beaufort County, Op. No. 28204 (May 15, 2024), the Court held that a party’s...

What It Takes: The Algebra of Great Lawyering

By Christian Stegmaier

May 15, 2024

SUMMARY The algebra of great lawyering is the blend of incredible competence, powerful relationships, and effective communication. This formula is the key to excelling in the competitive, evolving legal landscape. Deep practice focus and carving out a niche enables lawyers...

A South Carolina woman’s attempt to change her story in a trip-and-fall lawsuit backfired when the Court of Appeals upheld the trial court’s ruling excluding what it called a “Sham Affidavit” submitted in opposition of the defendant’s motion for summary...

In the wake of recent campus demonstrations over the Israeli-Palestinian conflict, universities across the nation are facing challenges in managing protests that balance safety, free speech, and civil discourse. As lawyers who have represented several colleges and universities in South...

Prom  and graduation season is an exciting time for teenagers, filled with anticipation, glamour, and often, a desire for freedom and fun. For parents, it can be a challenging time too, especially when it comes to ensuring their child's safety...

What It Takes The Golden Rolodex: Stagnation and Succession in Defense Law Firms The world of defense law firms can be a gilded cage. Senior partners, armed with years of experience and a rolodex overflowing with client contacts, reign supreme....

The Interplay of Rules 5 and 36

By Kelsey Brudvig

June 23, 2023

In a recent unpublished decision from the Court of Appeals, a defendant successfully argued that once counsel appears in the case, all papers must be served upon counsel. In Mayers v. Henthorn, Op. No. 2023-UP-177 (S.C. Ct. App. May 11,...

Are you a company that utilizes independent contractors in your operations? The South Carolina Supreme Court now says you may be held liable in the negligent selection of your independent contractor. On June 21, 2023, the South Carolina Supreme Court...

The Interplay of Rules 5 and 36

By Kelsey Brudvig

June 23, 2023

In a recent unpublished decision from the Court of Appeals, a defendant successfully argued that once counsel appears in the case, all papers must be served upon counsel. In Mayers v. Henthorn, Op. No. 2023-UP-177 (S.C. Ct. App. May 11,...

WeWork, the once-high-flying co-working company that was once valued at $47 billion, has filed for Chapter 11 bankruptcy protection, marking a dramatic end to a chapter in one of Silicon Valley's once most promising (and curious) startups. The company's fall...

The Interplay of Rules 5 and 36

By Kelsey Brudvig

June 23, 2023

In a recent unpublished decision from the Court of Appeals, a defendant successfully argued that once counsel appears in the case, all papers must be served upon counsel. In Mayers v. Henthorn, Op. No. 2023-UP-177 (S.C. Ct. App. May 11,...

How to make your restaurant website accessible to individual with disabilities. The importance of ADA compliance in the digital space has grown in recent years, as more and more people rely on the internet for information and services. For restaurant...

What Is Third Space? The term "Third Space" refers to a hybrid space that combines elements of the first two spaces (home and work) to create a third space that is neither home nor work but is a place where...

Organized Retail Crime: A Primer and 2023 Update

By Christian Stegmaier

April 28, 2023

As law enforcement in the 2020s focuses on the rise in drug trafficking and other offenses, criminal organizations have increasingly turned to retail crime to generate illicit profits by using internet-based tools to steal merchandise, sell stolen goods, and move...

The Interplay of Rules 5 and 36

By Kelsey Brudvig

June 23, 2023

In a recent unpublished decision from the Court of Appeals, a defendant successfully argued that once counsel appears in the case, all papers must be served upon counsel. In Mayers v. Henthorn, Op. No. 2023-UP-177 (S.C. Ct. App. May 11,...

Are you a company that utilizes independent contractors in your operations? The South Carolina Supreme Court now says you may be held liable in the negligent selection of your independent contractor. On June 21, 2023, the South Carolina Supreme Court...

Here’s the scenario: An employee commits an intentional act that is criminal in nature while on the clock.  A third party is injured by this act.  The employer is sued based on a theory of vicarious liability.  The act was...

On Missing Insured in South Carolina

By Collins & Lacy, P.C.

November 6, 2019

Attorneys here at Collins & Lacy act as defense counsel. That means we represent individuals and businesses who have been sued. More often than you may think, we have a hard time finding a person who is being sued.   Last...

Court holds plaintiffs must prove three types of commonality Liability of a successor entity under South Carolina’s “mere continuation” rule continues to require commonality of ownership. However, the door may have been opened for successor liability in the absence of...

South Carolina law does not require punitive damages be apportioned pro rata between bodily injury and property damage in a split limits automobile insurance policy. In Government Employees Insurance Company v. Poole, 2018 WL 3300235, (S.C., 2018), the South Carolina...

SPECIAL REPORT: Reservation of Rights

By Kelsey Brudvig

January 23, 2017

Insurer's failure to advise policyholder of its interest in allocated damages results in coverage for general verdict. The South Carolina Supreme Court has concluded that: (1) an insurance company’s reservation of rights letter was insufficient and the insured had therefore...

The Fourth Circuit Court of Appeals recently held that an insurer had a duty to defend an insured against class action allegations that the insured posted confidential medical records on the Internet. Two patients at Glen Falls Hospital discovered that...

The South Carolina Court of Appeals has concluded that notice of cancellation of a homeowner’s insurance policy is controlled by S.C. Code § 38-75-1160, not the more general § 38-75-740, and that the mortgage holder was not the homeowner’s agent...

In Evanston Ins. Co. v. Agape Sr. Primary Care, Inc., No. 14-2268, 2016 WL 192748 (4th Cir. Jan. 15, 2016), the Fourth Circuit affirmed the South Carolina District Court’s finding that a professional liability policy provided coverage to the innocent...

An auto insurer had no duty to defend a trucking company against an injured driver’s claim because the insurance policy excluded claims by “employees,” notwithstanding that the driver was technically an independent contractor. Progressive Mountain Ins. v. Madd Transp. LLC,...

A South Carolina federal district court judge has ordered that Nationwide must pay an accident victim $1.1 million, in excess of the $50,000 Nationwide policy, as a result of Nationwide’s failure to timely respond to a time-limited settlement demand. Urena...

Imagine: an employee is injured in a car accident with another driver who is at fault.  The employee settles with the at-fault driver for the limits of her liability policy.  The employee, whose injuries exceed the at-fault driver’s liability limits,...

An insurer cannot require contribution from a co-insurer for the expenses of an insured’s defense where one insurer denies liability and the other refuses to defend, according to a recent opinion of the Fourth Circuit Court of Appeals, affirming a...

An insured’s failure to make payments on his life insurance policy led it to lapse before his death according to Fourth Circuit Court of Appeals in Wactor v. Jackson National Life Insurance Co., No. 13-2367, 2015 WL 1020653 (4th Cir....

UberX may have passed one of the primary roadblocks to its business operations in South Carolina – meeting the state’s insurance requirements. In July 2014, UberX, a ridesharing service, expanded into South Carolina, offering transportation in four of the state’s...

An insurance company may not seek to require another insurer to defend its insured via declaratory judgment according to the United States District Court for the District of South Carolina in Auto-Owners Insurance Company v. Travelers Casualty and Surety Company...

The S.C. Court of Appeals reversed and remanded a half million dollar verdict against a homeowner’s insurance company because the fire chief was allowed to testify regarding his opinion on causation. Fowler v. Nationwide Mutual Fire Ins. Co., Op. No....

The S.C. Court of Appeals recently applied the “your work” exclusion in a declaratory judgment action arising out of a construction defect suit to find the policy did not provide coverage. In Precision Walls v. Liberty Mutual Fire Insurance Co.,...

The Eleventh Circuit Court of Appeals reversed a Florida district court’s award of damages to the excess insurer on the ground that the excess insurer failed to prove the primary insurer’s alleged bad faith had caused the excess insurer damages....

The S.C. Supreme Court declined to adopt the doctrine of reasonable expectations within the insurance coverage context in Bell v. Progressive Direct Insurance Co., Op. No. 27381 (S.C. Sup. Ct. filed April 9, 2014). Instead, the court held the doctrine...

A Florida automobile insurance policy’s family exclusion did not violate South Carolina public policy according to an April 2014 opinion of the South Carolina Supreme Court. In Green v. United States Automobile Association Auto and Property Insurance Company, a motor...

In an unpublished opinion, the 4th Circuit Court of Appeals reversed a South Carolina District Court judge’s finding that an insurer was equitably estopped from denying coverage to a new owner of the insured business for a wrongful death claim....

Court Not Amused by Lawyers’ Appellate Brief

By Kelsey Brudvig

November 12, 2013

A medical equipment provider sued an insurer to recover assigned first-party no-fault benefits. The insurer appealed from an order denied its cross-motion for summary judgment. The order was essentially affirmed. However the court, on its own motion, ordered the plaintiff’s...

A Commercial General Liability (CGL) policy did not provide coverage when a brick face was damaged by improper cleaning after the insured completed its installation according to a recent opinion of the South Carolina Supreme Court. Finding exclusions j.(5) and...

In Liberty Mutual Fire Insurance Company v. J M smith Corporation, No. 7:12-2824-TMC, 2013 WL 5372768 (D.S.C.), Liberty Mutual filed a declaratory judgment action against its insured in South Carolina Federal Court.  The suit sought a finding that the State of...

Methamphetamines vs. Narcotics – The Sequel

By Collins & Lacy, P.C.

June 21, 2013

S.C. Supreme Court Reverses S.C. Court of Appeals; Holds Methamphetamine Is Not a Narcotic The plain and ordinary meaning of narcotic in an insurance policy does not include methamphetamine according to a June 12, 2013 opinion of the S.C. Supreme...

A title insurance company busted in its attempt to recover losses stemming from thefts to support a gambling problem inProctor v.Whitlark and Whitlark, Inc., App. Case No. 2012-205510, 2013 WL 2017335 (S.C. Ct. App. May 15, 2013). Post by Peter...

A D&O endorsement excluded coverage for claims alleging damage to other property as a result of defective design or construction. According to a May 8, 2013 opinion of the S.C. Court of Appeals, coverage for allegations against the insured for breach...

The Fourth Circuit has affirmed a Virginia district court’s decision, finding the conviction of an insured in an underlying criminal case ended an insurer’s obligation to pay defense costs pursuant to a D&O policy. Farkas v. Nat’l Union Fire Ins....

Contractual limitation of a home inspector’s liability does not violate South Carolina public policy and, as a matter of law, is not unconscionable, according to a March 2013 opinion of the S.C. Supreme Court. Finding such limit of liability clauses...

Insurers and insureds have occasion to dispute whether lawsuits between them are subject to arbitration clauses in insurance policies. While Landers v. FDIC did not involve an insurance policy, the South Carolina Supreme Court’s holding that an employee’s breach of...

Fourth Circuit Rules in Favor of Insurer, Finding Attorney Fees Incurred in DJ Action May Be Considered in Determining Controversy Amount Calculation of the amount in controversy was at issue in a recent Fourth Circuit ruling. According to the March 2013 opinion in Francis...

Number of Occurrences addressed in Surgical Tools Snafu

By Collins & Lacy, P.C.

March 22, 2013

If you are going into surgery, you probably have some concerns, but you may not have thought to worry about whether the surgical instruments had been washed in elevator hydraulic fluid rather than proper surgical detergents and lubricants. An interesting case from...

South Carolina municipalities are not entitled to assess municipal business license taxes based on, or measured by, the total flood insurance premiums collected in the particular municipality by insurance companies under an arrangement with FEMA, according to a March 1,...

S.C. Court Finds Insufficient Proof in Life Insurance Fraud Case

By Collins & Lacy, P.C.

February 1, 2013

S.C. Court of Appeals says Jury Could Conclude Insured Did Not Make Misrepresentations on Life Insurance Application With Fraudulent Intent In a recent opinion, the South Carolina Court of Appeals found a jury could reasonably conclude a life insurance company insurer was...

Post by Lee Floyd Two key goals in subrogation are attaining swift resolution of the claim and avoiding unnecessary activities before and during the lawsuit. Doing this can minimize the effort before a lawsuit is filed so that the claim can...

Finds City Did Not Waive Governmental Immunity by Purchasing Liability Insurance Policies In a December 17, 2012 opinion, the U.S. Court of Appeals for the Fourth Circuit found the City of Durham did not waive its governmental immunity by purchasing...

UPDATE as of July 31, 2014: On December 12, 2012, the plaintiffs petitioned the South Carolina Supreme Court to issue a writ of certiorari. The Supreme Court granted certiorari on June 25, 2014. Accordingly, this decision may be modified or...

S.C. Statute Requiring CGL Policies to Contain a Specific Definition of “Occurrence” Held Constitutional; Retroactive Application of Statute Held Unconstitutional In a recent decision, Harleysville Mutual Insurance Co. v. South Carolina, (Opinion 27189, Nov. 21, 2012), the South Carolina Supreme...

Photo by StockVault As you are preparing for Thanksgiving and worrying you will accidentally burn the 15 pounds of turkey you have spent hours dressing, just remember, it could be worse. You could burn four million pounds of turkey. That’s...

Governor Nikki Haley has named Ray Farmer as the new director of the South Carolina Department of Insurance. Farmer takes over on December 3, 2012 after retiring as Southeast vice president of the American Insurance Association. Governor Haley made the announcement yesterday,...

Pollution Exclusion Drives Homeowners Batty

By Collins & Lacy, P.C.

November 7, 2012

Homeowners in Lake Tomahawk, Wisconsin walked in to their house one day to find an “offensive odor emanating from the home.” The cause of the odor was bat guano that had accumulated between the home’s siding and walls, making “the...

Beware of Things that Go Bump in the Night

By Collins & Lacy, P.C.

October 30, 2012

It is almost Halloween, and chances are your neighborhood will be full of trick-or-treaters going door-to-door filling up their bags with treats of all kinds. Unfortunately, Halloween also is the night for tricks. One particular trick made it all the...

Finds Conversion Exclusion Does Not Exclude Coverage to Loss Payee When the Loss Resulted From Primary Insured’s Intentional Burning of Insured Trucks On October 4, 2012, in an unpublished opinion, the U.S. Court of Appeals for the Fourth Circuit affirmed...

On September 12, 2012, the South Carolina Supreme Court, on certification from the U.S. District Court for the District of South Carolina, held the insured’s damages arising out of a title insurance suit should be measured as of the date...

Pete Dworjanyn Collins & Lacy attorney and Insurance Practice Group Chair Pete Dworjanyn will speak this week at the 2012 Primerus Defense Institute (PDI) Seminar on Insurance Coverage and Bad Faith. The seminar is September 20-21, 2012 in Chicago, Illinois....

S.C. District Court Finds Insured Car Dealer’s Alleged Violation of S.C. Code §§ 56-15-10 to 600 and S.C. Code § 37-2-307 Not Covered Under Truth in Lending or Leasing Provision of E&O Endorsement   On September 10, 2012, the United...

Statute of Limitations on Patient Records for Minors

By Collins & Lacy, P.C.

August 21, 2012

The South Carolina Physicians' Patient Records Act provides SECTION 44-115-120: Length of time records must be kept; records pertaining to minors. It details the length of time records must be kept. Here is a refresher on the rules of the Act....

S.C. Appellate Court Holds Insurer’s Duty to Pay Not Triggered Where Insured as to Liability Coverage Not Liable to a Third Party On August 1, 2012, the South Carolina Court of Appeals affirmed the decision of the trial court, holding...

Post by Pete Dworjanyn Directors and Officers policies are typically claims-made policies which attempt to exclude coverage for wrongful acts which occur after the inception of the policy but arise from a nucleus of facts which preceded the inception of...

The Fourth of July is fast approaching, and so our thoughts turn to fun, freedom, and of course, fireworks. With that in mind, this post discusses a 2002 opinion of the United States Court of Appeals for the Fourth Circuit...

Finds “Business Use” Exception to the Policy Applies to Bar Coverage for Accident While Under Dispatch On June 27, 2012, in an unpublished opinion, the United States Court of Appeals for the Fourth Circuit ruled in favor of an insurer...

In a 3-2 decision, the South Carolina Supreme Court has concluded that public policy is offended by a portability limitation clause which purports to prevent non-resident relatives from importing UIM coverage from an at-home vehicle’s policy when the involved vehicle...

Boyd v. Liberty Life and SelectQuote

By Kelsey Brudvig

June 18, 2012

The South Carolina Court of Appeals has concluded that an authorization to an insurance company to draft premium amounts from a checking account was insufficient consideration to form a contract for life insurance. Boyd v. Liberty Life Insurance Company and...

Negotiate Before You Mediate

By Collins & Lacy, P.C.

June 11, 2012

In the 35 years I’ve been practicing law, mediation has dramatically changed the number of critical cases tried to a jury conclusion.  In South Carolina, mediation has become almost a center point of trial practice.  In my home town of...

Charleston grocery store prevails in CGL dispute

By Collins & Lacy, P.C.

June 8, 2012

A Charleston grocery store prevailed in a recent ruling involving a coverage dispute after a shooting in the store. In Pennsylvania National Mutual Casualty Insurance Company v. DOSCHER'S SUPER MARKETS, Dist. Court, D. South Carolina 2012, Anita Thorne, as Guardian...

Here is Part II of our blog series regarding Jessco, Inc. v. Builders Mutual Insurance Co. You can read Part I here, which details a recent opinion of the United States Court of Appeals for the Fourth Circuit that addresses...

A recent opinion of the United State Court of Appeals for the Fourth Circuit addressed a multitude of issues presented in litigation involving commercial general liability policies – the “your work” exclusion, late notice, and the duty to indemnify. On...

Post by Pete Dworjanyn In June, I will be part of the Collins & Lacy team presenting a Continuing Legal Education (CLE) to the Association of Corporate Counsel entitled "Managing Your Risks: A 2012 Perspective on Business, Social Media and...

Don’t Just Ignore Compliant Requests

By Collins & Lacy, P.C.

May 4, 2012

Sometime ago, I wrote a blog article on the new Code Section 38-77-250, which requires automobile insurance companies to disclose, prior to suit, the limits of coverage pursuant to specific requests.  Since then, I have had a number of inquiries...

On April 17, 2012, in Barber v. American Family Home Insurance Co., the United States District Court for the District of South Carolina, inter alia, granted the cross-defendant’s motion to dismiss crossclaims. The subject of the amended complaint and counterclaim...

Fourth Circuit Finds Insured’s Participation in Investment Scheme Triggers Business Enterprise Exclusion Under Professional Liability Policy On March 29, 2012, in an unpublished opinion, the United States Court of Appeals for the Fourth Circuit affirmed the judgment of the Eastern...

Subrogation in South Carolina Series: Part II Post by Lee Floyd An initial question when evaluating and bringing a subrogation claim is who are the proper parties to identify as bringing suit?  While ordinarily a fairly simple question in most...

Subrogation Claims in South Carolina

By Collins & Lacy, P.C.

March 19, 2012

Lee Floyd South Carolina law recognizes the doctrine of subrogation in the context of insurance as permitting an insurer to recover amounts it has paid for loss by bringing an action against the tortfeasor(s) whose wrongful act caused the loss.[1] At...

In a decision published February 24, 2012, the United States Court of Appeals for the Fourth Circuit held that an insured’s violation of the Fair Labor Standards Act (“FLSA”) constituted a “wrongful act” under the terms of the defendant school...

Last Friday, February 3, 2012, the United States Court of Appeals for the Fourth Circuit [1] filed its opinion in Pennsylvania National Mutual Casualty Insurance Company v. Roberts, in which the Court declined to apply the tort doctrine of “joint...

Is Your Golf Cart an Uninsured Motor Vehicle?

By Collins & Lacy, P.C.

February 2, 2012

With the growing use of golf carts outside the boundaries of golf courses, it is worth some discussion about whether a golf cart is a motor vehicle. If it is, could it be an “uninsured motor vehicle” under an automobile insurance policy...

Fourth Circuit Rules in Favor of Insurer That Refused to Defend Inmate Finds Inmate Is Not Covered as a “Volunteer Worker” On January 20, 2012, in an unpublished opinion, the United States Court of Appeals for the Fourth Circuit ruled...

The homepage of SC Lawyers Weekly today has an article relating to Collins & Lacy attorney Jack Griffeth's recent post about a little-known element of the newly-enacted South Carolina Fairness in Civil Justice Act of 2011, which became effective January...

We handle a fair amount of litigation involving Undersinsured Motorist Coverage (UIM).  Occasionally, we see the "buyer's remorse" theme.  A motorist is injured due to fault of another, and the motorist's loss is not adequately compensated by the at-fault party's bodily injury liability policy.  The motorist, having remorse over his failure...

On December 28, 2011, David Black resigned as director of the South Carolina Department of Insurance. Governor Nikki Haley had nominated Black to the position 11 months earlier. His appointment was confirmed by the South Carolina Senate in February 2011....

New Punitive Damages now in Effect

By Collins & Lacy, P.C.

January 5, 2012

The new year brings new changes regarding punitive damages. Effective January 1, 2012, there are significant changes to the law concerning punitive damage awards in South Carolina. The changes are a result of the South Carolina Fairness in Civil Justice...

The Fourth Circuit Court of Appeals recently affirmed a South Carolina District Court judge’s grant of summary judgment to an insurer based on an endorsement excluding coverage for any obligation assumed in connection with an insurance contract or treaty, or...

A Burning Need: Pay Attention to Insurance Coverage Policy Terms

By Collins & Lacy, P.C.

December 8, 2011

I read an interesting article in the Wall Street Journal Law Blog, “No Fire Fee? Let Your House Burn!" about a fire department in South Fulton, Tennessee that watched a house burn because the owners had not paid a $75.00...

The South Carolina Court of Appeals has issued an opinion that lawsuits against insurance companies in South Carolina must be served through the South Carolina Department of Insurance. The opinion was premised on two code sections. S.C. Code § 38-5-70...

On September 6, 2011, the United States Court of Appeals for the Fourth Circuit amended its March 24, 2011 opinion in Bryan Brothers, Inc. v. Continental Casualty Co., which held that the prior knowledge provision in a policy is a...

Post by Lee Floyd At first blush, it might not seem that a healthcare professional liability insurance policy would cover injuries due to alleged sexual misconduct by a healthcare professional. Instead, one might assume such conduct would not be considered...

Last time, we discussed The AES Corporation v. Steadfast Insurance Company, a recent Virginia case where the growing trend of climate change nuisance cases intersected with the world of insurance coverage law. Critical to the coverage analysis was whether the...

An environmental case that started in an Alaskan fishing village of less than two square miles and less than 400 residents landed in the Supreme Court of Virginia. That court issued an opinion that could impact the growing trend of climate change...

Methamphetamines vs. Narcotics – What do they mean anyway?

By Collins & Lacy, P.C.

October 18, 2011

Post by Lee Floy Hello all! I'm Lee Floyd, a self-admitted sports junkie who practices law at the Collins & Lacy Columbia office. When I'm not wake boarding or playing golf in my spare time, I'm enjoying the company of...

Production of Adjuster Personnel Files in Insurance Litigation

By Collins & Lacy, P.C.

October 7, 2011

It is well known that discovery can be one of the most expensive and time-consuming parts of the litigation process. Often, an insurer is faced with requests for sensitive material that seem to test the limits of the Federal Rules’...

Greetings from Greenville, S.C.! On June 14, 2011, the South Carolina Fairness in Civil Justice Act of 2011 was signed into law. The Act will become effective on January 1, 2012, making significant changes to the law concerning punitive damage...

Post by Pete Dworjanyn The South Carolina Supreme Court has issued an opinion holding that defective construction resulting in property damage to non-defective components may be covered by a general liability policy. On August 22, 2011, the court withdrew its...

Welcome to the South Carolina Insurance Law Blog!

By Collins & Lacy, P.C.

September 21, 2011

Greetings! Welcome to the South Carolina Insurance Law Blog. Our goal is to provide you with timely information and updates on legal issues related to the practice of insurance coverage. We look forward to sharing out thoughts with you, and...

Fireworks Liability

By Andrew T. Smith

December 27, 2022

With the holidays upcoming, everyone is certain to have a favorite tradition.  From wrapping presents to the tunes of Bing Crosby’s Christmas album, to waking up on January 1st feeling like your brain lost a fight with King Kong, the...

The Interplay of Rules 5 and 36

By Kelsey Brudvig

June 23, 2023

In a recent unpublished decision from the Court of Appeals, a defendant successfully argued that once counsel appears in the case, all papers must be served upon counsel. In Mayers v. Henthorn, Op. No. 2023-UP-177 (S.C. Ct. App. May 11,...