State v. Casey L. Combs

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

The State, Respondent,

v.

Casey Lee Combs, Appellant.

Appellate Case No. 2024-001992

Appeal From Charleston County
Jennifer B. McCoy, Circuit Court Judge

Unpublished Opinion No. 2026-UP-025
Submitted January 2, 2026 – Filed January 28, 2026

AFFIRMED

Elizabeth Anne Franklin-Best, of Elizabeth Franklin-
Best, P.C., of Columbia, for Appellant.

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

PER CURIAM: Casey Lee Combs appeals the circuit court's order revoking his
probation. On appeal, he argues the circuit court abused its discretion when it
revoked his probation without making any findings of fact or articulating a
standard of review. We affirm pursuant to Rule 220(b), SCACR.
We hold the circuit court did not abuse its discretion when it revoked Combs's
probation because a sufficient evidentiary basis supported the circuit court's
finding that he had violated the terms of his probation. See State v. Allen, 370 S.C.
88, 94, 634 S.E.2d 653, 655 (2006) ("The determination of whether to revoke
probation in whole or part rests within the sound discretion of the [circuit] court.");
id. at 94, 634 S.E.2d at 656 ("An appellate court will not reverse the [circuit]
court's decision unless that court abused its discretion."); id. ("An abuse of
discretion occurs when the [circuit] court's ruling is based upon an error of law,
such as application of the wrong legal principle; or, when based upon factual
conclusions, the ruling is without evidentiary support; or, when the [circuit] court
is vested with discretion, but the ruling reveals no discretion was exercised; or
when the ruling does not fall within the range of permissible decisions applicable
in a particular case, such that it may be deemed arbitrary and capricious."); id. at
94, 634 S.E.2d at 655 ("The [circuit] court must determine whether the State has
presented sufficient evidence to establish that a probationer has violated the
conditions of his probation."); State v. Hill, 368 S.C. 649, 658, 630 S.E.2d 274, 279
(2006) ("[P]robation is properly revoked upon an evidentiary showing of facts
tending to establish a violation."); State v. Pauling, 371 S.C. 435, 439, 639 S.E.2d
680, 682 (Ct. App. 2006) (indicating that in probation revocation hearings, "the
evidence is often limited to the testimony of a probation officer or . . . affidavits of
victims or police officers"); State v. Williamson, 356 S.C. 507, 509-12, 589 S.E.2d
787, 788-89 (Ct. App. 2003) (concluding a sufficient evidentiary basis supported
the circuit court's finding that the appellant had violated the conditions of his
probation when he had been arrested on a charge but had not been convicted of that
charge).

AFFIRMED.1

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

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