State v. Ryan Lenard Manigo

Summary

The South Carolina Court of Appeals dismissed Ryan Lenard Manigo's appeal as arising from an interlocutory order that was not immediately appealable. The court held that Manigo, a pretrial detainee, could not demonstrate cognizable prejudice before trial, conviction, or sentencing, and noted that issues concerning publicity and admissibility could be addressed through later proceedings.

Holdings

1. The order was an interlocutory order that was not immediately appealable under South Carolina law because it did not constitute a final judgment and did not fall within an exception in section 14-3-330.
2. The court declined to reach the merits of the remaining arguments because dismissal of the appeal on appealability grounds was dispositive.

Questions Presented

1. Whether the circuit court's order permitting release of Manigo's pretrial telephone calls was a final or otherwise immediately appealable order.
2. Whether the appeal should be dismissed as premature because Manigo had not yet been tried, convicted, or sentenced.

Disposition

dismissed