TRASK v. BEAUFORT COUNTY

No. 4799.

392 S.C. 560 (2011)

709 S.E.2d 536

L. Paul TRASK, Jr., Personally, and as Next of Kin and as the Duly Appointed Personal Representative of the Estate of L. Paul Trask, III, deceased; and Meredith C. Trask, Appellants, v. BEAUFORT COUNTY; Curtis M. Copeland in His Official Capacity as Coroner of Beaufort County; Judy R. Copeland, as Personal Representative of the Estate of Curtis M. Copeland; and Copeland Company of Beaufort, LLC, Respondents.

Court of Appeals of South Carolina.

Decided March 2, 2011.

Rehearing Denied June 3, 2011.


Attorney(s) appearing for the Case

Stephen P. Groves , Thomas S. Tisdale, Jr. , and Jeffrey S. Tibbals , all of Charleston, for Appellants.

Andrew F. Lindemann , of Columbia; and Marshall H. Waldron, Jr. , of Beaufort; for Respondents.


FEW, C.J.

The primary issue in this appeal is whether various statutes governing coroners and crematory operators give rise to private rights of action for civil damages. We agree with the circuit court that they do not, and affirm. We also affirm the circuit court's ruling granting summary judgment for the defendants for spoliation of evidence and intentional infliction of emotional distress.

I. Facts

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