David Stokes v. Oconee County

Syllabus

In this defamation action, Appellant David T. Stokes seeks review of the circuit court's rulings granting summary judgment to Respondents Wayne McCall and Edda Cammick and denying Stokes's motion to amend his complaint. Stokes also challenges the circuit court's ruling quashing a subpoena Stokes served on the Administrator for Respondent Oconee County (the County). Stokes argues that (1) Councilman McCall and Councilwoman Cammick were not entitled to immunity under the South Carolina Tort Claims Act because their alleged misconduct fell outside the scope of these council members' official duties (2) the proposed amendment to his complaint would not have been futile because the alleged defamatory statements were not material to the purpose of the meeting at which they were made and (3) Stokes was entitled to serve a subpoena on the County Administrator in his individual capacity because his prior deposition was taken in his capacity as a representative of the County pursuant to Rule 30(b)(6), SCRCP. We affirm the circuit court's orders granting summary judgment to McCall and Cammick and denying the motion to amend. We decline to address the circuit court's ruling quashing the subpoena as it is not immediately appealable.