Supreme Court of South Carolina

Lt. J.a. Fleming, Jr., Respondent v. Boykin Rose and James Caulder, Defendants, of Whom Boykin Rose Is, Petitioner

July 22, 2002350 S.C. 488

Summary

The court reversed the Court of Appeals and reinstated summary judgment for Rose on Fleming's libel claim. Because Fleming was a public official, he had to present clear and convincing evidence that Rose published the press release with actual malice, meaning knowledge of falsity or reckless disregard for truth; the court held the evidence did not meet that standard.