South Carolina Public Interest Foundation v. Calhoun County Council, 854 S.E.2d 836

In the November 2018 general election, Calhoun County voters approved a 1% "penny" sales and use tax to fund fifteen listed projects.
Appellants (South Carolina Public Interest Foundation and individuals) challenged four listed projects (Sandy Run ladder truck, Sandy Run tanker truck, county ambulance purchases, and an 800 MHz emergency communications project) as unauthorized under S.C. Code § 4-10-330.
The county certified the referendum results by resolution on November 26, 2018.
The Foundation filed a declaratory judgment action on April 3, 2019 (nearly four months after certification) seeking invalidation of the four projects and to enjoin collection of the penny tax.
The County moved to dismiss under the thirty-day limitations provision in § 4-10-330(F); the circuit court held the suit was time-barred and did not reach the merits.
The Supreme Court of South Carolina affirmed, holding the thirty-day limitations period applied to this substantive challenge and barred the action.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 4-10-330(F)'s 30-day limitations period bars the Foundation's challenge to four listed projects	The 30-day limit applies only to procedural/election irregularity challenges (e.g., vote count), not to substantive challenges over whether listed projects are authorized	§ 4-10-330(F) contains no procedural/substantive distinction; it bars suits attacking the "results of the referendum" unless filed within 30 days	The 30-day limitations period applies to all challenges to the referendum results (including substantive challenges); the Foundation's suit, filed after 30 days, is time-barred

Hite v. Town of West Columbia, 220 S.C. 59 (1951) (rejected narrow reading that limited short limitations period to vote-counting only; applied to entire annexation process)
Morgan v. Feagin, 230 S.C. 315 (1956) (upheld short limitations for challenges after voter approval of bond-related proceedings)
State ex rel. Condon v. City of Columbia, 339 S.C. 8 (2000) (statutory limitations bars late challenges; limitations promote timely enforcement)
Amisub of S.C., Inc. v. S.C. Dep't of Health & Envtl. Control, 407 S.C. 583 (2014) (statutory construction: ascertain legislative intent; apply plain language when unambiguous)
Town of Mt. Pleasant v. Roberts, 393 S.C. 332 (2011) (courts must give statutory text its plain and ordinary meaning)
State v. County of Florence, 406 S.C. 169 (2013) (court will not judicially engraft requirements not found in statute)