Ziegler v. Dorchester County, 828 S.E.2d 218

Dorchester County placed a single ballot question in the Nov. 8, 2016 election authorizing up to $30M in general obligation bonds for library facilities and up to $13M for recreational facilities (combined into one question totaling $43M).
State Senator Paul Thurmond requested an Attorney General opinion; the AG concluded separate votes are required for distinct bond purposes.
Appellants (local residents and taxpayer groups) sued before the election seeking declaratory and injunctive relief, arguing the single-question referendum unlawfully combined separate bond propositions; no hearing was held before the election and the referendum passed (≈60%).
Circuit court granted defendants’ Rule 12(c) motion, finding the question was not misleading and voters understood it; Appellants appealed to the Supreme Court of South Carolina.
The Supreme Court considered whether state law and precedent require separate referendum questions for distinct bond purposes and whether the combined question was lawful; bonds had not yet been issued.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the combined referendum question complied with S.C. law	The ballot unlawfully joined two distinct bond propositions (libraries and recreation) and voters must be allowed to vote on each separately	The question was clear and voters understood it; home-rule authority permits local administration of bond referenda	The combined question was unlawful; distinct bond propositions must be submitted as separate referendum questions

Ross v. Lipscomb, 83 S.C. 136, 65 S.E. 451 (1909) (municipal bond propositions that are distinct must be submitted as separate questions)
S.C. Dep't of Transp. v. Revels, 411 S.C. 1, 766 S.E.2d 700 (2014) (court cited as persuasive authority on municipal-law principles)
Jowers v. S.C. Dep't of Health & Envtl. Control, 423 S.C. 343, 815 S.E.2d 446 (2018) (justiciability principles confirming courts may reach merits when controversy exists)