Fairfield 132 v. Haley Surface, 2022-001303

Fairfield 132 Smith Street, LLC sued Haley Surface, Jill Surface, Hannah Glickman, and Diane Glickman regarding an alleged breach of a lease agreement.
Summary judgment was granted to Fairfield by the Charleston County Circuit Court on April 22, 2022, without indication a formal order would follow.
The Surface and Glickman defendants (Appellants) filed a timely motion to reconsider, which was denied on June 4, 2022.
Over two months later, on August 17, 2022, the circuit court issued a full written order with findings and damages awards.
Appellants argued there were unresolved factual issues regarding breach, liability of co-signers, and damages/mitigation.
The appellate court found the circuit court lost jurisdiction ten days after denying the motion to reconsider (absent a reservation of jurisdiction), rendering the later written order void.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Breach of lease/disputed facts	Breach occurred as alleged.	Disputed extent of breach and facts.	Not reached; circuit court lacked jurisdiction
Joint and several liability of co-signers	Co-signers are jointly and severally liable.	Liability of co-signers is disputed.	Not reached; circuit court lacked jurisdiction
Damages entitlement and mitigation	Entitled to claimed damages, mitigation adequate.	Disputed amount and mitigation efforts.	Not reached; circuit court lacked jurisdiction
Jurisdiction of the circuit court	Order valid and within court's authority.	Court lacked jurisdiction when issuing August order.	Circuit court lost jurisdiction after 10 days; order vacated

Russell v. Wachovia Bank, N.A., 370 S.C. 5 (S.C. 2006) (discussing when circuit court loses jurisdiction post-judgment)
Leviner v. Sonoco Prods. Co., 339 S.C. 492 (S.C. 2000) (court's limited power to alter/amend judgments after 10 days under Rule 59(e))
Ness v. Eckerd Corp., 350 S.C. 399 (S.C. Ct. App. 2002) (jurisdictional loss post entry of judgment without reservation)