Johnathan M. Daniels v. City of Cayce

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

Johnathan M. Daniels, Appellant,

v.

City of Cayce, Respondent.

Appellate Case No. 2024-000168

Appeal From Lexington County
Debra R. McCaslin, Circuit Court Judge

Unpublished Opinion No. 2026-UP-092
Submitted January 2, 2026 – Filed February 25, 2026

AFFIRMED

Johnathan M. Daniels, of Columbia, pro se.

Danny Calvert Crowe, of Garfield Spreeuwers Law
Group, LLC, of Columbia, for Respondent.

PER CURIAM: Johnathan M. Daniels appeals the circuit court's order dismissing
his appeal from the Cayce Municipal Court's (1) denial of Daniels's pretrial
motions to quash and dismiss his charges of driving without a license and driving
without a vehicle registration, and (2) grant of City of Cayce's (City's) motion to
limit evidence and argument before the jury. On appeal, Daniels argues (1) the
municipal court erred in failing to grant his motions because City substantially
burdened his religious beliefs and practices, (2) the municipal court did not have
jurisdiction over his charges, and (3) he was denied his right to a jury trial. We
affirm pursuant to Rule 220(b), SCACR.

We hold the circuit court did not err in dismissing Daniels's appeal because Daniels
filed his appeal before a sentence or judgment was imposed by the municipal court.
See State v. Green, 436 S.C. 492, 494, 872 S.E.2d 869, 869 (Ct. App. 2022) ("Our
standard of review in criminal cases is limited to correcting errors of law."); S.C.
Code Ann. § 14-25-95 (2017) ("Any party shall have the right to appeal from the
sentence or judgment of the municipal court to the Court of Common Pleas of the
county in which the trial is held." (emphasis added)). The municipal court's rulings
on Daniels's and City's motions were not final, could be overturned, and were not
immediately appealable. Furthermore, although Daniels asserts he was denied his
right to a jury trial as he could not properly present his defense, Daniels was still
permitted to present his free exercise of religion defense at a later junction during
trial, and he was not denied his right to a jury trial. See State v. Isaac, 405 S.C.
177, 183, 747 S.E.2d 677, 680 (2013) ("[G]enerally, a criminal defendant may not
appeal until [a] sentence is imposed."); id. at 183, 747 S.E.2d at 679 ("An order
involving the merits 'must finally determine some substantial matter forming the
whole or a part of some cause of action or defense.'" (quoting Mid-State Distrib.,
Inc. v. Century Imp., Inc., 310 S.C. 330, 334, 426 S.E.2d 777, 780 (1993))); cf. id.
at 183, 747 S.E.2d at 679 ("An order denying an immunity request [under the
Protections of Persons and Property Act] is not an order involving the merits in
that it does not finally determine a substantial cause of action or defense.").
Additionally, although Daniels asserts these rulings were immediately appealable
under section 14-3-330(2) of the South Carolina Code (2017), they did not
"prevent[] a judgment from which an appeal might be taken or discontinue[] the
action" or "strike[] out an answer or any part thereof or any pleading in any action"
because Daniels was not denied his right to a jury trial and could still present his
defense and file an appeal if the jury convicted him. See § 14-3-330(2) ("The
Supreme Court shall have appellate jurisdiction for correction of errors of law in
law cases, and shall review upon appeal . . . (2) An order affecting a substantial
right made in an action when such order (a) in effect determines the action and
prevents a judgment from which an appeal might be taken or discontinues the
action, (b) grants or refuses a new trial or (c) strikes out an answer or any part
thereof or any pleading in any action . . . ."). 1

1
Because we hold the circuit court did not err in dismissing Daniels's appeal since
the municipal court's rulings were not immediately appealable, we have not
addressed Daniels's remaining arguments concerning his free exercise of religion
AFFIRMED.2

WILLIAMS, C.J., and THOMAS and CURTIS, JJ., concur.

defense. See Futch v. McAllister Towing of Georgetown, Inc., 335 S.C. 598, 613,
518 S.E.2d 591, 598 (1999) (explaining an appellate court does not need to address
remaining issues when its resolution of a prior issue is dispositive of the appeal).
2
We decide this case without oral argument pursuant to Rule 215, SCACR.