Bruce Wilson v. Joseph Bledsoe
CourtCourt of Appeals of South Carolina
Date FiledOctober 21, 2026
Docket2023-001585
StatusUnpublished
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Full Opinion
THIS OPINION HAS NO PRECEDENTIAL VALUE. IT SHOULD NOT BE
CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING
EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.
THE STATE OF SOUTH CAROLINA
In The Court of Appeals
Bruce Wilson, Appellant,
v.
Joseph Hunter Bledsoe, Respondent.
Appellate Case No. 2023-001585
Appeal From Greenville County
Perry H. Gravely, Circuit Court Judge
Unpublished Opinion No. 2026-UP-457
Submitted September 1, 2026 – Filed October 21, 2026
AFFIRMED
Bruce Wilson, of Greenville, pro se.
Kenneth Jay Anthony, of Anthony Law, LLC, of
Greenville, for Respondent.
PER CURIAM: Bruce Wilson appeals the circuit court's order affirming the
magistrate's dismissal of his claim and delivery action on the basis that he failed to
identify the specific property allegedly taken and its value. On appeal, Wilson
argues the circuit court abused its discretion by dismissing his claim because
section 22-3-1460 of the South Carolina Code (2025) does not require him to
produce receipts or credit card statements to prove ownership or value of the
property in question. We affirm.
We hold that the Claim and Delivery Section does not require Wilson to provide
sales receipts, credit card statements, or any other evidence of proof of purchase to
establish ownership and value. However, Wilson's claim was properly dismissed
because he failed to provide sworn testimony or any other evidence to identify the
items taken, their value, or proof of ownership of those items. First Palmetto State
Bank & Tr. Co. v. Boyles, 302 S.C. 136, 138, 394 S.E.2d 313, 314 (1990) ("An
action in claim and delivery is an action at law for the recovery of specific personal
property."); Clerks' Benevolent Union v. Knights of Columbus, 70 S.C. 543, 547,
50 S.E. 206, 207 (1905) (holding that in order for a plaintiff to recover, he "must
allege that the property detained is his, or that it was taken from his possession, and
he cannot recover without showing title in himself"); Manship v. Newsome, 188
S.C. 6, 10, 198 S.E. 428, 430 ("Proof of title, or right of possession, is a
prerequisite to a plaintiff prevailing in an action in [c]laim and [d]elivery."); see
also S.C. Code Ann. section 22-3-1320 (2006) ("[T]he plaintiff . . . shall make
proof by affidavit, showing: (1) [t]hat the plaintiff is the owner or is entitled to
immediate possession of the property claimed, particularly describing such
property . . . and (5) [t]he actual value of such personal property."); see Bossard v.
Vaughn, 68 S.C. 96, 46 S.E. 523 (1904) (holding sections 22-3-1320 and
22-3-1460 of the S.C. Code (2006) can be satisfied by referring back to the
pleadings in a claim and delivery action). There is no evidence in the record of
ownership or value of the property other than Wilson's unnotarized affidavit and
complaint. The circuit court found Wilson failed to testify to the actual value of
the items in question or otherwise provide "any evidence" to support his claim
despite being given "numerous opportunities" at trial and on remand to do so. The
factual finding that Wilson did not establish ownership of any items taken or their
values is supported by the evidence, and there are no facts that show the affirmance
was influenced by an error of law. See Union Cnty. Sheriff's Off. v. Henderson,
395 S.C. 516, 519, 719 S.E.2d 665, 666 (2011) (explaining a "magistrate's factual
findings, confirmed by the circuit court, must be upheld by the appellate court if
supported by any evidence"); Hadfield v. Gilchrist, 343 S.C. 88, 93, 538 S.E.2d
268, 271 (Ct. App. 2000) ("[T]he [appellate court] will presume that an affirmance
by a [c]ircuit [c]ourt of a magistrate's judgment was made upon the merits where
the testimony is sufficient to sustain the judgment of the magistrate and there are
no facts that show the affirmance was influenced by an error of law." (quoting
Burns v. Wannamaker, 281 S.C. 352, 357, 315 S.E.2d 179, 182 (Ct. App. 1984))).
AFFIRMED.1
WILLIAMS, C.J., and MCDONALD and TURNER, JJ., concur.
1
We decide this case without oral argument pursuant to Rule 215, SCACR.