In a recent ruling, the South Carolina Court of Appeals affirmed the dismissal of an appeal filed by inmate Bernard Jackson against the South Carolina Department of Corrections (DOC). The court's decision, issued in an unpublished opinion on November 4, 2026, centered on a dispute regarding Jackson's wages and the handling of his earnings. This ruling has implications for how inmate wage disputes are managed within the state's correctional system.

Jackson, who represented himself in the case, argued that he was entitled to receive ten percent of his earnings to be deposited into a long-term savings account. This claim arose after he signed a settlement agreement with the DOC, which stipulated that the total settlement amount would be deposited into his inmate account, with specific deductions already made for victim restitution and room and board.

The dispute reached the Court of Appeals after the Administrative Law Court (ALC) dismissed Jackson's appeal based on a stipulation of dismissal that had been filed. The ALC concluded that the stipulation, which Jackson had previously agreed to, effectively ended the appeal process. Jackson's objection to the stipulation led to the appeal being filed in the higher court.

Background

The parties involved in this case are Bernard Jackson, an inmate at a South Carolina correctional facility, and the South Carolina Department of Corrections, the state agency responsible for managing the state's prison system. Jackson's case revolved around the handling of his wages earned while incarcerated.

Jackson claimed that he was entitled to a portion of his wages to be set aside in a long-term savings account. However, the DOC argued that the settlement agreement he signed clearly stated that the total settlement amount would be deposited into his inmate account, and no additional funds would be allocated for long-term savings. This disagreement over the interpretation of the settlement agreement led to the appeal.

The case was initially heard by the ALC, which ruled in favor of the DOC after determining that the stipulation of dismissal filed by both parties effectively resolved the matter. Jackson's appeal to the Court of Appeals followed this ruling, as he sought to challenge the ALC's decision.

The Ruling

The South Carolina Court of Appeals ruled to affirm the ALC's dismissal of Jackson's appeal. The court noted that the stipulation of dismissal was binding, as Jackson had agreed to it and it was properly filed with the ALC. The court emphasized that, according to Rule 43(k) of the South Carolina Rules of Civil Procedure, settlement agreements must be either entered into the court's record or acknowledged in open court to be enforceable.

The court stated, "We find no error by the ALC in dismissing pursuant to the stipulation of dismissal."

The judges who participated in this ruling were Thomas, Konduros, and Curtis, who all concurred with the decision. Their agreement highlighted the importance of adhering to procedural rules regarding settlement agreements in legal proceedings.

Impact

This ruling has significant implications for inmates and their ability to dispute wage-related issues within the South Carolina correctional system. By affirming the ALC's dismissal, the Court of Appeals reinforced the necessity for inmates to understand the terms of any agreements they enter into with the DOC. It also underscores the importance of following legal procedures when it comes to settlement agreements.

The decision may serve as a precedent for similar cases in the future, particularly those involving wage disputes and the handling of inmate earnings. It emphasizes that once an agreement is reached and properly documented, it is binding and can limit the ability of inmates to challenge the terms later on.

What's Next

Details were not available in the court filing regarding whether Jackson plans to appeal this decision further. However, given the nature of the ruling, it is unlikely that there will be a related case pending that could alter the outcome of this decision.