In a recent ruling, the South Carolina Court of Appeals dismissed the appeal of Ryan Lenard Manigo, a pretrial detainee facing multiple serious charges, including five counts of murder. The court's decision came after Manigo contested the release of his jail telephone calls to the media, claiming it violated his constitutional rights. This ruling is significant as it highlights the legal complexities surrounding pretrial detainees and their rights to privacy.
Manigo, who has been held at the Colleton County Detention Center since his arrest on July 2, 2023, is facing a total of 17 charges, including arson, criminal sexual conduct, and kidnapping. The media's release of his jail calls prompted him to appeal the circuit court's decision allowing such disclosure. Manigo's argument centered on the belief that these calls should not be subject to the Freedom of Information Act (FOIA) and that their release infringed upon his rights under both state and federal law.
The case reached the Court of Appeals after the circuit court ruled in favor of the media's access to Manigo's calls. The court's decision to dismiss the appeal was based on the determination that the circuit court's order was an interlocutory order, meaning it was not a final decision and therefore not immediately appealable under South Carolina law.
Background
The parties in this case are the State of South Carolina, represented by Attorney General Alan McCrory Wilson and his team, and Ryan Lenard Manigo, represented by Chief Attorney S. Boyd Young and Capital Defender Robert Louis Bank, Jr. The dispute arose when the media obtained and released recordings of Manigo's jail telephone conversations, prompting him to argue that this violated his rights.
Manigo's appeal was based on several claims, including that the release of his calls violated his constitutional rights to privacy and due process. He also argued that the calls should be exempt from FOIA due to their nature as pretrial detainee communications. The case was brought to the Court of Appeals after the circuit court allowed the release of the calls, which Manigo contended was erroneous.
The Ruling
The South Carolina Court of Appeals ruled to dismiss Manigo's appeal, stating that the circuit court's order allowing the release of the pretrial telephone calls was not immediately appealable. The court explained, "An appeal may be taken, as provided by law, from any final judgment, appealable order or decision." The judges emphasized that, in South Carolina, a criminal defendant cannot appeal until a conviction and sentence have been imposed.
Judge Thomas, along with Judges McDonald and Turner, concurred in the decision. They noted that the circuit court's order was an interlocutory order, which relates to intermediate matters in the case and does not constitute a final judgment. The court further clarified, "We do not see how Manigo can prove that any error by the circuit court resulted in prejudice to him as he has not yet been tried, convicted, or sentenced." This statement underscores the court's position that without a final judgment, the appeal lacks merit.
Impact
The dismissal of Manigo's appeal has implications for other pretrial detainees and their rights regarding privacy and media exposure. The ruling establishes that pretrial detainees may not have the same protections against media scrutiny as those who have been convicted. It also reinforces the legal principle that appeals in criminal cases are typically not allowed until after a final judgment has been made.
This ruling may set a precedent for future cases involving pretrial detainees and the release of their communications. It raises questions about the balance between public interest and the rights of individuals awaiting trial. The court's decision indicates that while pretrial publicity can be a concern, it does not automatically warrant an appeal unless it can be shown to cause actual prejudice to the defendant.
What's Next
Manigo's legal team may consider their options moving forward, including the possibility of addressing the issues raised in his appeal during the trial itself. The court's ruling does not prevent Manigo from raising these concerns later in the legal process. As of now, there are no indications that the case will be appealed further, but the legal landscape surrounding pretrial rights and media access remains a topic of interest.