Martha M. Coleman v. Jeffrey W. Coleman

── Martha M. Coleman v. Jeffrey W. Coleman ── Court: Supreme Court of South Carolina Date: May 13, 2026 Category: General 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 Supreme Court Martha M. Coleman, Respondent, v. Jeffrey W. Coleman and Brooks Walters, Defendants, of whom Jeffrey W. Coleman is a Respondent, and Brooks Walters is the Petitioner. Appellate Case No. 2025-001911 Appeal from Sumter County Thomas M. Bultman, Family Court Judge Memorandum Opinion No. 2026-MO-006 Heard April 21, 2026 – Filed May 13, 2026 REVERSED J. Michael Taylor, of Taylor/Potterfield, of Columbia, and Ryan Alexander McLeod, of McDougall, Self, Currence & McLeod, LLP, of Sumter, both for Petitioner Brooks Walters. Christopher Ryan DuRant, of Johnson DuRant, LLC, of Manning, for Respondent Martha M. Coleman. PER CURIAM: We granted a writ of certiorari to review the court of appeals' decision in Coleman v. Coleman, Op. No. 2025-UP-228 (S.C. Ct. App. filed July 9, 2025). We reverse the family court's order holding Petitioner in contempt and grant Petitioner's motion to dismiss based on lack of personal jurisdiction. Having carefully canvassed the Appendix, it is clear Petitioner does not have any contacts—minimum or otherwise—with South Carolina. In fact, his only contact with the state was during a quasi-administrative action filed by Respondent with the South Carolina Department of Social Services (DSS), in which DSS ordered Petitioner to attend a "negotiation conference" to establish his paternity over the child at issue. Because DSS stated the alternative was a default order establishing paternity and obligating him to pay child support, Petitioner sent his attorney to the conference, but he declined to take the requested paternity test. DSS ultimately dismissed the action without taking issue with Petitioner's non-compliance. When subsequently named as a party to this action, Petitioner raised a personal jurisdiction defense at his earliest opportunity. Notwithstanding the complete lack of any evidence establishing Petitioner's voluntary and substantial contacts with South Carolina, the family court denied the motion to dismiss and ordered Petitioner to submit to a paternity test. Petitioner refused. The family court then issued a rule to show cause and held a contempt hearing based on Petitioner's non-compliance. Of course, the right to appeal in a contempt proceeding arises not from the nature of the proceeding but from holding the contemnor in contempt. Thus, once the family court held him in contempt and it became clear there would be a final appealable order on which to base an appeal, Petitioner re-raised the same personal jurisdiction defense he had asserted from the outset of the case.1 Contrary to the court of appeals' finding, we reject any suggestion that Petitioner's argument is somehow foreclosed by either entering a "general appearance" in the non-judicial DSS action 2 or by our 1 Judge Bultman presided at the final hearing on Petitioner's motion to reconsider the contempt finding. Although Judge Bultman incorrectly believed he was bound by the finding of personal jurisdiction by the prior judge at the temporary hearing, he repeatedly expressed strong concerns about the family court's exercise of jurisdiction over Petitioner. 2 See, e.g., 4 Am. Jur. 2d Appearance § 2 (Feb. 2026 Update) ("A party enters a general appearance when he (1) invokes the judgment of the court on any question other than the court's jurisdiction, (2) recognizes by his acts that an action is properly pending, or (3) seeks affirmative action from the court." (emphasis added)). issue preservation rules. 3 Cf. Welch v. Advance Auto Parts, Inc., 445 S.C. 640, 658, 916 S.E.2d 320, 330 (2025