Carpenter v. SCDC

Syllabus

Charles Carpenter alleges he is being unlawfully held in prison because his sentences for conspiracy in trafficking cocaine and conspiracy in trafficking marijuana have expired. He raised these allegations in two separate civil actions: a petition for writ of habeas corpus and a declaratory judgment action. After a bench trial, the circuit court ruled Carpenter was procedurally barred from raising his allegations in a petition for a writ of habeas corpus, and even if not barred, his allegations lacked merit. The circuit court therefore granted declaratory judgment in favor of the South Carolina Department of Corrections (SCDC). Carpenter appeals these findings and also claims the circuit court erred in failing to rule on his declaratory judgment claims against the State and by failing to disclose a disqualifying bias in favor of the State. We affirm in part, vacate in part, and remand in part.