Eric Canty, 196262 v. SCDPPPS

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

Eric Canty, #196262, Appellant,

v.

South Carolina Department of Probation, Parole and
Pardon Services, Respondent.

Appellate Case No. 2024-000889

Appeal From The Administrative Law Court
Robert Lawrence Reibold, Administrative Law Judge

Unpublished Opinion No. 2025-UP-439
Submitted December 17, 2025 – Filed December 23, 2025

AFFIRMED

Eric Canty, pro se.

General Counsel Matthew C. Buchanan, of the South
Carolina Department of Probation Parole and Pardon
Services, of Columbia, for Respondent.

PER CURIAM: Eric Canty, pro se, appeals an order of the Administrative Law
Court (ALC) dismissing his appeal of a decision by the South Carolina Department
of Probation, Parole and Pardon Services (SCDPPPS) to deny him parole. On
appeal, Canty argues the ALC erred in finding SCDPPPS followed the proper
procedure in denying parole. We affirm pursuant to Rule 220(b), SCACR.

We hold the ALC did not err in dismissing Canty's appeal because the parole
board's order stated it considered all statutory and departmental factors in making
its decision, including the actuarial risk and needs assessment tool required by
section 24-21-10(F)(1) of the South Carolina Code (2025). See S.C. Code Ann.
§ 1-23-610(B) (Supp. 2025) (stating the circumstances under which this court may
reverse or modify a decision of the ALC); Cooper v. S.C. Dep't of Prob., Parole &
Pardon Servs., 377 S.C. 489, 500, 661 S.E.2d 106, 112 (2008) (stating that if the
parole board's decision to deny parole is a "routine denial of parole," then the
ALC's authority is limited to determining whether the board followed proper
procedure), abrogated on other grounds by Allen v. S.C. Dep't of Corr., 439 S.C.
164, 886 S.E.2d 671 (2023); id. (stating a denial of parole is routine if the board
"clearly states in its order denying parole that it considered the factors outlined in
section 24-21-640 [of the South Carolina Code] and the fifteen factors published in
its parole form"); Compton v. S.C. Dep't of Prob., Parole & Pardon Servs., 385
S.C. 476, 479, 685 S.E.2d 175, 177 (2009) (holding an order that denied parole and
stated that the SCDPPPS considered all statutory and departmental criteria was
sufficient to support a denial of parole); Cooper, 377 S.C. at 500, 661 S.E.2d at
112 ("[T]he [p]arole [b]oard may avoid [reversal] if it clearly states in its order
denying parole that it considered the factors outlined in section 24-21-640 and the
fifteen factors published in its parole form. . . . Under that scenario, the ALC can
summarily dismiss the inmate's appeal.").

AFFIRMED.1

KONDUROS, GEATHERS, and VINSON, JJ., concur.

1
We decide this case without oral argument pursuant to Rule 215, SCACR.