Horton v. Jasper County School DistrictAnnotate this Case
After Randy Horton won this action seeking the production of documents under the South Carolina Freedom of Information Act (FOIA), the circuit court awarded him attorneys' fees at a rate of $100 per hour. On appeal, the South Carolina Supreme Court addressed solely the question of whether the court abused its discretion in selecting that hourly rate. "When a trial court's decision is made on a sound evidentiary basis and is adequately explained with specific findings—as the law requires—we defer to the trial court's discretion. Here, however, there is no evidence in the record that supports the circuit court's reduction of the hourly rate." Rather than remand, the Court reversed the trial court and awarded Horton $35,611.50 in attorneys' fees and $1,096.56 in costs.