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Randall Williams, as Personal Representative of the Estates of Shanice R. Dantzler-Williams and Miranda R. Dantzler-Williams, et al. v. Charleston County Sheriff’s Office, et al.
Paid petition · United States Court of Appeals for the Fourth Circuit, No. 24-1238 · judgment February 25, 2025
Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.
Questions presented
In Hess v. Port Auth. Trans-Hudson Corp., 513 U.S. 30 (1994), the Court held that “the vulnerability of the State’s purse is the most salient factor” in Eleventh Amendment arm-of-the-state immunity analysis. Id. at 48. Respondent Charleston County Sheriffs’ Office (CCSO) is a department of Charleston County, and the County budgets, funds, insures, and indemnifies CCSO solely with County funds. The State of South Carolina is legally prohibited from paying any judgments against any county office, including CCSO. Nonetheless, the decision below held that CCSO was an arm of the state, yet did not consider this ‘most salient factor’ in its analysis. The questions presented are:
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When the State is not liable for a judgment against an entity, what weight should this fact be given in the arm-of-the-state immunity analysis of that entity.
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Whether the Charleston County Sheriff’s Office is an arm of the State of South Carolina for sovereign immunity purposes. (i)
Counsel of record
For petitioner
Richard Allan Hricik
Law Offices of Richard A. Hricik. PA
For respondent
Deborah Harrison Sheffield
Hood Law Firm, LLC
Case
Conference history
Distributed for 2 conferences
Proceedings
- Apr 24 2026Judgment Issued.
- Mar 23 2026Petition GRANTED. Judgment VACATED and case REMANDED for further consideration in light of Galette v. New Jersey Transit Corp., 607 U. S. ___ (2026).
- Mar 16 2026DISTRIBUTED for Conference of 3/20/2026.
- Jan 14 2026DISTRIBUTED for Conference of 2/20/2026.
- Jan 09 2026Reply of petitioners Randall Williams, et al. filed.
- Jan 02 2026Brief of respondent Charleston County Sheriff's Office in opposition filed.
- Dec 01 2025Petition for a writ of certiorari filed. (Response due January 2, 2026)