Joseph N. Grate v. Jameka Cohen ( 2023 )

THIS OPINION HAS NO PRECEDENTIAL VALUE. IT SHOULD NOT BE
CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING
EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.
THE STATE OF SOUTH CAROLINA
In The Court of Appeals
Joseph N. Grate, Appellant,
v.
Jameka Cohen, Respondent.
Appellate Case No. 2021-000449
Appeal From Georgetown County
Benjamin H. Culbertson, Circuit Court Judge
Unpublished Opinion No. 2023-UP-118
Submitted March 1, 2023 – Filed March 22, 2023
AFFIRMED
Joseph N. Grate, of Pawley's Island, pro se.
Jameka Cohen, of Pawley's Island, pro se.
PER CURIAM: Joseph N. Grate, pro se, appeals the circuit court's affirmance of
the magistrate court's order ruling that Jameka Cohen satisfied Grate's complaint
by providing her insurance information. On appeal, Grate argues (1) the
magistrate court erred in ruling Cohen's response satisfied his complaint, (2) the
circuit court erred in denying his motions for recusal and admission of best
evidence, and (3) the court reporter erred by lying in the production of the
transcript from his hearing in front of the circuit court. We affirm pursuant to Rule
220(b), SCACR.
1. We hold that Grate abandoned his argument that the magistrate court erred in
ruling Cohen's production of her insurance information satisfied his complaint.
See Glasscock, Inc. v. U.S. Fid. & Guar. Co., 348 S.C. 76, 81, 557 S.E.2d 689, 691
(Ct. App. 2001) ("[S]hort, conclusory statements made without supporting
authority are deemed abandoned on appeal and therefore not presented for
review."); State v. Colf, 332 S.C. 313, 322, 504 S.E.2d 360, 364 (Ct. App. 1998)
(finding a conclusory, two-paragraph argument that cited no authority other than
an evidentiary rule was abandoned), aff'd as modified on other grounds, 337 S.C.
622, 525 S.E.2d 246 (2000).
2. We hold Grate abandoned his arguments regarding the circuit court's denial of
his motion for admission of best evidence and his motion for recusal because he
made conclusory arguments, and he failed to cite authorities other than one
evidentiary rule in relation to the admission of best evidence and one appellate
court rule in relation to his motion to recuse. See Colf, 332 S.C. at 322, 504 S.E.2d
at 364 (finding a conclusory, two-paragraph argument that cited no authority other
than an evidentiary rule was abandoned).
3. We hold Grate's argument that the court reporter erred by lying in the
production of the transcript of the circuit court hearing is not appropriate for direct
appeal because Grate did not allege any errors by the circuit court and did not
properly challenge the accuracy of the transcript provided by the court reporter.
See Al-Shabazz v. State, 338 S.C. 354, 363, 527 S.E.2d 742, 747 (2000) ("In a
direct appeal, the focus generally is upon the propriety of rulings made by the
circuit court in response to a party's motions or objections."); Rule 607(i), SCACR
(addressing retention of primary and backup tapes of a proceeding and the time for
a party to challenge the accuracy of the transcript).
AFFIRMED. 1
WILLIAMS, C.J., VERDIN, J., and LOCKEMY, A.J., concur.
1
We decide this case without oral argument pursuant to Rule 215, SCACR.