State v. Ryan L. Manigo (2)

Syllabus

Ryan Lenard Manigo is a pretrial detainee currently being held in the Colleton County Detention Center. Manigo was arrested on July 2, 2023, and charged with five counts of murder, arson first degree, two counts of criminal sexual conduct first degree, two counts of criminal sexual conduct with a minor, two counts of kidnapping, six counts of possession of a deadly weapon in the commission of a violent crime, burglary first degree, attempted murder, and incest. The charges remain pending. Following the media's release of Manigo's jail telephone calls, he appealed, arguing the circuit court erred in failing to find that: (1) pretrial detainee telephone calls are not subject to the Freedom of Information Act (FOIA); (2) the release of pretrial detainee telephone calls violates the pretrial detainee's Federal and State Constitutional rights; (3) FOIA's statutory exemptions prevent the release of pretrial detainee telephone calls; and (4) the release of pretrial detainee telephone calls violates public policy. We dismiss.