Error Preservation in South Carolina: Beware the "Two Issue" Rule.

By Kirsten E. Small

Because I am an appellate lawyer, error preservation is the bane of my existence. I don't care if the trial judge excluded your evidence, kicked a puppy, or made the jury deliberate through the Clemson-Carolina game. If you don't preserve the error, I can't help you.

As of Monday, I no longer care if the judge awarded the plaintiff damages for breach of contract. We'll be appealing the unjust enrichment claim, too.

The Appellate Code: The Many Meanings of "Per Curiam"

By Kirsten E. Small

We all know that “per curiam” means “by the court.” But, to echo a 1960s hippie-type, what does “per curiam” really mean, man? What message, if any, is an appellate court conveying by issuing an opinion “per curiam”?


Fear not—I’ve got the super-secret decoder ring. Here, in a nutshell, are the various meanings of “per curiam.”