Background - This appeal arises from Stoney v. Stoney, where the court of appeals reversed the family court and ordered a new trial on multiple issues (417 S.C. 345, 790 S.E.2d 31 (Ct. App. 2016)). - Petitioners sought certiorari to review the court of appeals’ decision, arguing the court misapplied the governing standard of appellate review in family-court matters. - The South Carolina Supreme Court granted certiorari, found error in the court of appeals’ use of an "abuse of discretion" formulation for numerous issues (III–XI), and remanded for reconsideration under the correct standard. - The Supreme Court reaffirmed Lewis v. Lewis, which holds that appeals from family court are reviewed de novo (392 S.C. 381, 709 S.E.2d 650 (2011)), while preserving two limitations: trial judges are better positioned to assess credibility, and appellants bear the burden to show the preponderance of evidence opposes the trial court’s findings. - The Court clarified that Lewis does not change the standard for purely evidentiary or procedural rulings (e.g., admissibility, joinder, Rule 60 motions), which remain subject to abuse of discretion review. - The Supreme Court reversed the court of appeals and remanded for reconsideration applying de novo review, cautioning against conflating "de novo" with "abuse of discretion." ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---:|---| | Proper standard of appellate review for family-court decisions | Court of appeals should apply de novo review per Lewis | Court of appeals applied abuse of discretion to multiple findings | Reversed; de novo is the proper standard for family-court appeals | | Effect of misapplied standard on other rulings | One erroneous standard finding can create a domino effect invalidating related rulings | Court of appeals’ multi-issue reversals flowed from its repeated abuse-of-discretion framing | Court remanded to court of appeals to reassess all issues under de novo review | | Appellate court’s role on factual findings/credibility | Appellate court may make independent findings de novo but should respect trial judge’s credibility assessments | Trial court’s factual findings should be given weight because trial judge sees witnesses | De novo review permits independent factfinding, but trial judge’s credibility advantage and appellant’s burden remain intact | | Standard for evidentiary/procedural rulings | Such rulings fall under de novo (argued by some) | Evidentiary and procedural rulings reviewed for abuse of discretion | Confirmed: evidentiary/procedural rulings are reviewed for abuse of discretion | ### Key Cases Cited Lewis v. Lewis, 392 S.C. 381, 709 S.E.2d 650 (2011) (establishes de novo review for family-court appeals) Stoney v. Stoney, 417 S.C. 345, 790 S.E.2d 31 (Ct. App. 2016) (court of appeals decision under review) Stoney v. Stoney, 421 S.C. 528, 809 S.E.2d 59 (2017) (superseding opinion/vacated prior opinion) Broom v. Jennifer J., 403 S.C. 96, 742 S.E.2d 382 (2013) (evidentiary rulings in family court reviewed for abuse of discretion) * Dorman v. Dep't of Health & Envtl. Control, 350 S.C. 159, 565 S.E.2d 119 (Ct. App. 2002) (importance of correctly stating standard of review)