Jefferson Davis, Jr. v. SC Educational Credit

Syllabus

In this Freedom of Information Act (FOIA) litigation, Appellant Jefferson Davis, Jr. (Davis) appeals the circuit court's order granting summary judgment to Respondent South Carolina Educational Credit for Exceptional Needs Children Fund (the Fund). Davis contends the circuit court erred in (1) finding that the Fund is not covered by state law defining a \public body\ (2) finding that the Fund was not supported by public funds (3) finding that reporting requirements for the Department of Revenue could replace any FOIA obligations the Fund might have (4) finding that reporting requirements in a 2016-2017 budget proviso were sufficient to replace any FOIA obligations the Fund might have (5) finding that reporting requirements in a 2017-2018 budget proviso were sufficient to replace any FOIA obligations the Fund might have (6) taking into account later legislation when considering the intent behind the budget provisos governing the Fund and (7) misconstruing legislation that made the Fund permanent. We affirm.