ACLU v. Wilson
CourtSupreme Court of South Carolina
Date FiledSeptember 2, 2026
Docket2025-002469
StatusPublished
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Full Opinion
THE STATE OF SOUTH CAROLINA
In The Supreme Court
American Civil Liberties Union of South Carolina
Foundation,
Plaintiff,
v.
Alan Wilson, in his official capacity as South Carolina
Attorney General; Joel Anderson, in his official capacity
as Interim Director of South Carolina Department of
Corrections,
Defendants,
and
Henry McMaster, in his official capacity as Governor of
the State of South Carolina,
Intervenor.
Appellate Case No. 2025-002469
ON CERTIFICATION FROM THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF SOUTH CAROLINA
Hon. Joseph F. Anderson, Jr., United States District Judge
Opinion No. 28350
Heard June 16, 2026 – Filed September 2, 2026
CERTIFIED QUESTIONS ANSWERED
David Allen Chaney, Jr., and Meredith Dyer McPhail,
both of the American Civil Liberties Union of South
Carolina Foundation, of Columbia; and Jonathan E.
Spratley and Steven M. Cady, both of Williams &
Connolly LLP, of Washington DC, all for Plaintiff.
Austin Tyler Reed, Daniel Clifton Plyler, and Frederick
Newman Hanna, Jr., all of Smith Robinson Holler
DuBose Morgan, LLC, of Columbia, for Defendants
Alan Wilson, in his official capacity as South Carolina
Attorney General, and Joel Anderson, in his official
capacity as Interim Director of South Carolina
Department of Corrections.
Solicitor General Thomas Tyler Hydrick and Deputy
Solicitor General Joseph David Spate, both of Columbia,
for Defendant Alan McCrory Wilson, in his official
capacity as Attorney General.
Chief Legal Counsel William Grayson Lambert, Deputy
Legal Counsel Erica Wells Shedd, and Deputy Legal
Counsel Tyra S. McBride, all of the Office of the
Governor, of Columbia; and Thomas Ashley Limehouse,
Jr., of Limehouse LLC, of Charleston, all for Intervenor.
JUSTICE HILL: The South Carolina General Assembly has taken steps to
statutorily protect the identities of people participating in the planning or carrying
out of death sentences. Section 24-3-580 of the South Carolina Code (2025)
prohibits the knowing disclosure of "identifying information" about "a current or
former member of an execution team." Pursuant to Rule 244, SCACR, the United
States District Court for the District of South Carolina has certified the following
questions to us: (1) whether publicly available information can be considered
"identifying information" under subsection 24-3-580(A)(2); and (2) whether a
person can "knowingly disclose" publicly available information under subsection
24-3-580(C). We answer both questions "No."
I. Overview of Section 24-3-580
Before we address the certified questions, we note several things about § 24-3-580.
The statute establishes civil liability and criminal penalties for the knowing
disclosure of identifying information about current or former execution team
members. § 24-3-580(C). A 2023 amendment to the statute broadened its reach to
protect the identity of the suppliers of lethal injection drugs and other medical
material used in carrying out death sentences and exempted these suppliers from
licensing and procurement regulations and other laws. See § 24-3-580(A)(1), (D)–
(F).
II. Whether publicly available information can be considered
"identifying information" under subsection 24-3-580(A)(2)?
In interpreting a statute, our first task is to look to its language. As Judge Friendly
reminded, every journey of statutory interpretation should begin with three steps:
"(1) Read the statute; (2) read the statute; (3) read the statute!" Henry J. Friendly,
Benchmarks 202 (1967). If the language is clear and plain, there is no need to look
beyond the text of the statute to divine its meaning. Smith v. Tiffany, 419 S.C. 548,
555–56, 799 S.E.2d 479, 483 (2017). A statute's words must be construed in context
and in light of the intended purpose of the statute and in harmony with its subject
matter. In re Manigo, 398 S.C. 149, 157, 728 S.E.2d 32, 36 (2012); see also Antonin
Scalia & Bryan A. Garner, Reading Law: The Interpretation of Legal Texts 56
(2012) ("[W]ords are given meaning by their context, and context includes the
purpose of the text.").
We hold that publicly available or nonconfidential information is not "identifying
information" within the meaning of subsection 24-3-580(A)(2). The statute defines
"identifying information" as including "any record or information that reveals a
name, date of birth, social security number, personal identifying information,
personal or business contact information, or professional qualifications" and "any
residential or business address; any residential, personal, or business telephone
number; any residential, personal, or business facsimile number; any residential,
personal, or business email address; and any residential, personal, or business social
media account or username" of an execution team member. § 24-3-580(A)(2).
Importantly, the statute does not define "identifying information" as a record or
information that includes or contains certain data (such as the name or address) of
an execution team member. Instead, it defines "identifying information" as any
record or information that reveals such data.
The use of the verb "reveal" is therefore significant. We construe undefined
statutory words based on their ordinary and popular meaning. See Adkins v. Varn,
312 S.C. 188, 191, 439 S.E.2d 822, 824 (1993) ("[W]ords must be given their plain
and ordinary meaning without resort to a subtle or forced construction which limits
or expands the statute's operation"). Reveal means "to make (something secret or
hidden) publicly or generally known." Reveal, Merriam-Webster Dictionary,
https://www.merriam-webster.com/dictionary/reveal (last visited July 12, 2026); see
reveal, The American Heritage Dictionary,
https://www.ahdictionary.com/word/search.html?q=reveal (last visited July 12,
2026) (defining reveal as "[t]o make known (something concealed or unknown)").
This definition aligns with the legislature's use of the word reveal in other statutes
that protect confidential information. See, e.g., S.C. Code Ann. § 44-117-360 (2018)
(providing, in a section of the Prescription Information Privacy Act entitled
"Improper revealing of confidential information," certain licensing consequences if
a licensee "allows the divulging or revealing of confidential information" regarding
a patient's prescription information or other health care information); S.C. Code Ann.
§ 60-4-10 (2022) (providing, in a statute entitled "Records identifying library patrons
as confidential information; disclosure," that library registration and circulation
records that contain "names or other personally identifying details regarding the
users" of library systems supported by public funds or records that "would reveal the
identity of the library patron checking out or requesting an item from the library or
using other library services are confidential information" and may not be "disclosed"
except in certain situations). Accordingly, the use of the word reveal supports the
interpretation that "identifying information" must not have previously been publicly
known or must have been confidential.
The legislature's use of "reveal" parallels its use of "disclose"—a synonym of
"reveal"—in other subsections of the statue. See § 24-3-580(C) ("A person shall not
knowingly disclose the identifying information of a current or former member of an
execution team or disclose a record that would identify a person as being a current
or former member of an execution team."); § 24-3-580(G) ("Notwithstanding any
other provision of law, including the South Carolina Freedom of Information Act,
Section 30-4-10, et seq., no department or agency of this State, no political
subdivision, and no other government or quasigovernment entity shall disclose the
identifying information of any member of an execution team or any details regarding
the procurement [of the lethal injection drugs]."). Disclose means "to make known
or public." Disclose, Merriam-Webster's Dictionary, https://www.merriam-
webster.com/dictionary/disclose (last visited July 12, 2026); see disclose, The
American Heritage Dictionary,
https://www.ahdictionary.com/word/search.html?q=disclose (last visited July 12,
2026) (defining disclose as "1. To expose to view, as by removing a cover; uncover.
2. To make known (something heretofore kept secret)"). As with its use of the word
"reveal," the legislature's use of "disclose" supports the conclusion that "identifying
information" must be information that is confidential, private, or unknown to or not
accessible by the general public. Both "reveal" and "disclose" derive from—and are
antonyms of—ancient French words meaning, respectively, to veil and close. See
13 Reveal, Oxford English Dictionary (2d. ed. 1989); 4 Disclose, Oxford English
Dictionary (2d. ed. 1989).
Because one cannot reveal something that is already known to the public, it follows
that to reveal identifying information one must release information that was
confidential or private up to the moment it was released. Here we are assisted by
the General Assembly's express intent, for the statute commands that it "shall be
broadly construed by the courts of this State so as to give effect to the General
Assembly's intent to ensure the absolute confidentiality of the identifying
information of any person or entity directly or indirectly involved in the planning or
execution of a death sentence within this State." § 24-3-580(I). This firms up our
conclusion that the identifying information referenced in the statute is confidential,
known only to the small circle of people that the South Carolina Department of
Corrections (SCDC) has deemed entitled to possess it, or has otherwise been kept
private by SCDC or the execution team member. In general, publicly available
information is information that has lost its confidential nature.
This interpretation also comports with the title of § 24-3-580, other subsections of §
24-3-580, and 2023 S.C. Acts No. 16, § 1, the Act that amended the statute to its
current form, which all stress the importance of "identifying information" being kept
"confidential" or private. § 24-3-580 (entitled "Execution team and drugs used to
administer death sentence confidential"); § 24-3-580(B) (providing "any identifying
information of a person or entity that participates in the planning or administration
of the execution of a death sentence shall be confidential" and not "subject to
discovery, subpoena, or any other means of legal compulsion or process. . . ."); 2023
S.C. Acts No. 16, § 1 (providing "the intent of this section is to ensure the absolute
confidentiality of identifying information of persons or entities involved in the
planning or execution of a death sentence . . ."); see confidential, Merriam-Webster's
Dictionary, https://www.merriam-webster.com/dictionary/confidential, (last visited
July 12, 2026) (defining confidential as "intended for or restricted to the use of a
particular person, group, or class: private, secret"); Confidential, Black's Law
Dictionary (12th ed. 2024) (defining confidential as "(Of information) meant to be
kept secret; imparted in confidence"); Confidential Information, Black's Law
Dictionary (12th ed. 2024) (defining confidential information as "[k]nowledge or
facts not in the public domain but known to some, esp. to those having a fiduciary
duty not to misuse the knowledge or facts for their own advantage").
Therefore, applying the plain and ordinary meaning of the words the legislature
chose to use, we hold § 24-3-580 unambiguously provides that public or
nonconfidential information cannot be "identifying information."
III. Whether a person can "knowingly disclose" publicly available
information, such that they are subject to the civil and criminal
penalties defined in subsection 24-3-580(C)?
As we have seen, § 24-3-580 uses the word "disclose" twice. See § 24-3-580(C) and
(G). The plain language of the statute supports the interpretation that "identifying
information" cannot be disclosed unless the information was confidential, private,
or unknown to or not accessible by the general public before the disclosure. This,
along with the legislature's use of the word "reveal" and its overt intent to keep
"identifying information" confidential, supports our conclusion that the legislature
did not intend for § 24-3-580 to apply to public or nonconfidential information.
We therefore hold that it would appear only the first person to publicly disclose
"identifying information"—i.e., the source of the disclosure or revelation—can
violate subsection 24-3-580(C). Once such information has been disclosed and
becomes publicly available, the information ceases to be "identifying information"
covered by the statute because it is no longer confidential or private.
IV. Conclusion
We hold (1) "identifying information" as defined in subsection 24-3-580(A)(2) does
not include publicly available or nonconfidential information, and (2) a person
cannot "knowingly disclose" such publicly available or nonconfidential information
under subsection 24-3-580(C). We thank Judge Anderson for certifying the
questions to us, and we commend the parties and their counsel for presenting the
issues in a concise and collegial manner. The certified questions are
ANSWERED.
KITTREDGE, C.J., JAMES, VERDIN, JJ., and Acting Justice Thomas W.
Cooper, Jr., concur.