Scannergate

Caption and Petition for Writ of Certiorari (p. 1-1)

No. __________

In the Supreme Court of the United States ________________________

JAMES C. MCNEIL AND MEAGHAN POYER,
Petitioners, v.
COURT OF COMMON PLEAS OF SOUTH CAROLINA, NINTH
JUDICIAL CIRCUIT, CHARLESTON COUNTY,
Respondent. ___________________________________________

ON PETITION FOR WRIT OF CERTIORARI
TO THE SUPREME COURT OF SOUTH CAROLINA
___________________________________________

PETITION FOR WRIT OF CERTIORARI
___________________________________________

James C. McNeil Meaghan Poyer P.O. Box 30386 Charleston, SC 29417 (843) 818–3495 chris@thaut.io

Pro Se Petitioners

AUGUST MMXXVI

Question Presented (p. 2-2)

QUESTION PRESENTED
Whether the Due Process and Equal Protection Clauses of the Fourteenth Amendment permit a court to reserve electronic access for licensed attorneys, forcing self-represented litigants to use a paper intake that degrades the integrity of evidentiary exhibits central to their claims.

Parties to the Proceedings (p. 3-3)

PARTIES TO THE PROCEEDINGS
Petitioners are James C. McNeil and Meaghan Poyer, individuals residing in Charleston County, South Carolina. Petitioners appeared as petitioners in the original-jurisdiction proceeding below and appear here pro se. Respondent is the Ninth Judicial Circuit Court of Common Pleas, Charleston County, South Carolina, the respondent in the original-jurisdiction proceeding below.

Related Proceedings (p. 3-3)

RELATED PROCEEDINGS
Court of Common Pleas of South Carolina (9th Jud. Cir., Charleston Cty.): McNeil v. SAC 181, LLC, No. 2025–CP–10–05095 (Aug. 3 and 14, 2026) (civil action filed Sept. 9, 2025; order of dismissal with prejudice entered Aug. 3, 2026; timely motion to alter or amend the judgment under Rule 59(e), SCRCP, filed Aug. 12, 2026 and denied Aug. 14, 2026; pro- ceeding presents distinct questions of sanctions and pleading sufficiency, and the relief sought here lies outside its scope) Supreme Court of South Carolina: McNeil v. Ninth Judicial Circuit Court of Com- mon Pleas, Charleston County, No. 2026– 000919 (May 21, 2026) (petition for writ of mandamus filed Apr. 14, 2026; order declining to entertain the petition entered May 21, 2026; judgment under review)

Jurisdiction and Provisions Involved (p. 10-10)

JURISDICTION
The Supreme Court of South Carolina denied man- damus on May 21, 2026. This Court has jurisdiction under 28 U.  S.  C. § 1257(a).
CONSTITUTIONAL, STATUTORY, AND
REGULATORY PROVISIONS INVOLVED
This case involves U.  S. Const., Amdt. XIV, § 1; Title II of the Americans with Disabilities Act, 42 U.  S.  C. § 12132; 28 C.  F.  R. §§ 35.108, and 35.130(b)(7)(i). The case also involves the State’s electronic-filing access rule, stated in the SCE-File User Agreement: “Only licensed South Carolina attorneys who are properly registered with AIS may electronically file documents using SCE-File.” Verbatim quotations of authorities are reproduced in the Appendix at App. 39–41, and the access rule is reproduced in the Appen- dix at App.  42.

I. The underlying action (p. 11-11)

I. The underlying action On September 9, 2025, Petitioners commenced a civil action in the Charleston County Court of Com- mon Pleas against their former landlord and its prop- erty managers, No. 2025–CP–10–05095, pleading claims under the South Carolina Residential Land- lord and Tenant Act together with claims for fraudulent misrepresentation, breach of contract, retaliation, negligence, and invasion of privacy. Petitioners’ pleadings alleged the publication of photographs of their occupied home, including a photograph depicting Poyer, across more than two dozen rental-listing plat- forms. Petitioners litigated the action without counsel throughout.

II. The filing architecture (p. 11-12)

II. The filing architecture South Carolina operates an electronic filing system for its circuit courts. The SCE-File User Agreement states the access rule in one sentence: “Only licensed South Carolina attorneys who are properly registered with AIS may electronically file documents using SCE-File.” App.  42. A represented party’s filings therefore enter the court’s file as native digital documents: in full color when the source is in color, text-searchable, and time- stamped along the margin with an electronic-filing legend adjacent to an identifying blue stripe. A self-represented party in the same court hand- files paper. The Clerk of Court’s intake scanner converts each submission to an image that becomes the official court file. On this record, that conversion produced two effects. First, color photographic evidence entered the file as monochrome. Second, the resulting file pages entered the record as images of text rather than as text, unsearchable by any reader of the electronic file, including the court. The second effect affects both public visibility and the ability to copy and paste text. A represented party’s submission arrives in the court’s file as machine-readable text, which a reader can search, quote from, and copy directly. A self-represented party’s submission arrives as a picture of words, which supports none of those operations without further conversion, such as optical character recognition (OCR), which can introduce errors. The classification therefore reaches beyond how each party’s evidence looks in the record to the mechanical availability of each party’s language to the person drafting the order or to anyone wishing to quote from the text. In a sense, whichever record is legible becomes the record that exists.

III. The demonstration placed on the record (p. 12-16)

III. The demonstration placed on the record On May 11, 2026, Petitioners filed in the circuit court a Notice whose Part C described the disparity and whose Exhibit E demonstrated it. App.  49–54, 59–60. App.  51–54, sets out the step-by-step comparison of counsel’s e-filing path against the self-represented paper path. App.  53–56, presents four panels. Panel 1 shows a page of Petitioners’ hand-filed response as it appears in the court’s file: gray streaking, a scan line down the left margin, artifacts through the caption block. Panel 2 shows a page of defense counsel’s e-filed motion: crisp, with the marginal legend “ELECTRONICALLY FILED-2026 Apr 02 4:09 PM-CHARLES-
TON-COMMON PLEAS-CASE#2025CP1005095.”
Panel 3 shows the photograph at the center of the invasion-of-privacy count as it entered the court’s file through the scanner: streaky monochrome line-work in which the person at the center of the frame reads as a light-and-dark smudge. Panel 4 shows the same photograph as published on Realtor.com: a full-color interior in which a person with dark hair, wearing a mustard-gold garment, stands at the center of the frame. The court’s intake process reduced the photograph to one bit of information per point: black or white. Every shade be- tween, the 256 levels of gray a consumer scanner pre- serves by default, was discarded at intake. App.  53–56.
The demonstration entered the docket on May 11, 2026, and was served on all parties. The circuit court held it for 84 days before entering the order described in Part G below. App.  4, 57.

IV. The motions and the comparator (p. 17-18)

IV. The motions and the comparator Three filings frame the access record. On October 24, 2025, Petitioners filed a Motion for Leave to File a Second Amended Complaint. The motion stood unopposed on the docket for 179 days. On April 21, 2026, a defendant served a memorandum in opposition. As of May 21, 2026, the motion had been pending 209 days without ruling, hearing, or scheduling order. On January 30, 2026, Petitioner McNeil filed a Sup- plemental Motion for ADA Accommodations, sup- ported by clinical documentation of disability. App. 69–72. The motion requested two accommodations: electronic filing access and remote appearance. Both re- quests sought forms of electronic access that the SCE- File User Agreement reserves to licensed attorneys. The motion further proposed, as an alternative to full e-filing access, that filings sent by email to a designated Clerk of Court address be deemed filed upon receipt. App.  73–74. As of May 21, 2026, the motion had been pending 111 days without ruling. The docket records its dis- position on May 28, 2026, the day of the hearing, 118 days after filing. On April 2, 2026, defense counsel filed a Motion to Relieve Justine Tate as Counsel. The circuit court granted it on April 7, 2026: five days from filing to dis- position, in the same case, on the same docket, during the same period. The same period supplies a second pairing. On March 23, 2026, defense counsel requested remote appearance at a hearing by email, citing schedule restrictions, and the accommodation followed. Petitioners’ motion for the same accommodation, filed January 30, awaited disposition until May 28.

V. The mandamus proceeding (p. 18-19)

V. The mandamus proceeding On April 14, 2026, Petitioners filed in the Supreme Court of South Carolina, in that court’s original jurisdiction, a petition for a writ of mandamus directed to the Ninth Judicial Circuit Court of Common Pleas, Charleston County. Appellate Case No. 2026–
000919. The petition asked the court to compel rulings on the motions described above, to direct scheduling pursuant to normal procedures, and to preserve asset discovery and equitable relief. The petition presented the federal questions directly. It grounded the accommodation claim in Title II of the Americans with Disabilities Act, 42 U.  S.  C. § 12132, and stated that the circuit court’s inaction, “while granting defense counsel’s identical informal request within hours, violates both the statutory man- date and Equal Protection principles.” It grounded the access claim in the Fourteenth Amendment: “The Due Process Clause of the Fourteenth Amendment and Article I, Section 3 of the South Carolina Constitution guarantee litigants meaningful access to the courts.” On April 28, 2026, the Supreme Court of South Carolina issued a letter to the Charleston County Clerk of Court requesting a return to the petition, and its Clerk’s office transmitted that request to Petitioners by email the same day. App.  61. The court maintains an email channel for submissions in its proceedings; Petitioners submitted filings through it, and the court’s Clerk’s office corresponded with Petitioners through it throughout the proceeding. App.  60. On May 8, 2026, the Clerk of Court filed a Return through counsel, stating that the Return was made only on the Clerk’s behalf and that the relief sought consisted of judicial functions falling outside the Clerk’s ministerial duties.

VI. The judgment under review (p. 19-20)

VI. The judgment under review On May 21, 2026, the Supreme Court of South Carolina entered the order under review. App.  1–3. Five justices signed it. The order states its reasons in full: First, the court declined on scheduling grounds: Because the circuit court has scheduled a hearing on Petitioners’ motions for May 28, 2026, we decline to entertain this matter in this Court’s original juris- diction. See Rule 245, SCACR, and Key v. Currie, 305 S.  C. 115, 406 S.  E.  2d 356 (1991). Second, the court explained the delay: [T]he circuit court requires time to review and con- sider individual motions and any accompanying materials prior to issuing a dispositive ruling. Further- more, Charleston is a very large county, and Petitioners’ case is one of many pending before that court. The very fact that the circuit court has scheduled a hearing on Petitioners’ motions demonstrates that the circuit court is not ignoring Petitioners’ filings. Accordingly, seeking a writ of mandamus before this Court was unnecessary. Third, the court addressed Petitioners’ filing volume: Petitioners are further cautioned that their excessive filings likely contributed to any delays in the case. Our review of the underlying case in the Charleston County public index indicates that Petitioners have filed more than forty motions, notices, and other documents during the eight-month time frame that the case has been pending. The order closed with a warning: While Petitioners’ filings in the underlying case may not yet rise to the level of abusive, Petitioners are warned that this Court and the circuit court have the power to establish filing restrictions in the event that either court determines a litigant is a prolific or abusive filer. The order counted Petitioners’ filings. It counted no unruled motion and no elapsed day. The circuit court’s own filing inventory, later attached as Exhibit A to its August 3, 2026 order, lists 31 filings by Plaintiffs and 34 by the defense. App.  32–38.

VII. How the federal question was raised and passed on (p. 21-21)

VII. How the federal question was raised and passed on The question presented entered the mandamus proceeding on April 14, 2026, in a petition that invoked the Due Process Clause of the Fourteenth Amendment by name, presented the day counts, and presented the five-day comparator. It entered again through the May 11, 2026 Supplement, whose Section II heading placed the Fourteenth Amendment on the face of the filing and whose text identified “the unequal burdens of paper filing” borne by the self-represented parties against the procedural access afforded to counsel. The underlying demonstration, Part C and Exhibit E of the May 11, 2026 Notice, was on the circuit court’s docket in the case the mandamus proceeding concerned. App.  49–54, 57, 59–61. The court passed on the question by the May 21, 2026 order. It resolved the delay question on the merits of the record before it, attributing the elapsed time to the county’s size, the volume of Petitioners’ filings, and the ordinary requirements of judicial review, and it answered the access record with a caution ad- dressed to the unrepresented litigants. The order disposed of the proceeding finally. App.  1–3.

VIII. Proceedings after the judgment under review (p. 21-23)

VIII. Proceedings after the judgment under review A machine at the courthouse took a woman out of a photograph. Then a judge ruled against pro se Plain- tiffs based on her absence. The August 3, 2026 order of the circuit court ap- pears in this petition for one purpose: it is the ruling that acted on the degraded image. Denying leave to amend, the order characterized the invasion-of-pri- vacy claim: “allegations such as the Plaintiffs being depicted incidentally in a listing photograph, without being identified, do not rise to the level of a cognizable claim.” App.  30. On the court-file copy of the photograph, that read- ing is available: the scanner’s output shows an inte- rior with a smudge where a person stands. On the color original, a specific, identifiable person stands at the center of the frame of her own home. App.  53–56. The court-file page carries a typed caption directly above the photograph reading “Images of Meaghan.” App.  56. The chain on this record runs in four links, each doc- umented: (1) a state filing rule reserved electronic fil- ing to licensed attorneys, so Petitioners hand-filed pa- per; (2) the Clerk’s intake scanner converted the color photograph to monochrome line-work and produced text-unsearchable pages; (3) the person at the center of the photograph became an artifact in the official record; (4) the court found the Plaintiffs “depicted in- cidentally” and “without being identified,” and the claim was eliminated. The demonstration of the de- fect had been on the docket 84 days when the order issued. Two further records from the mandamus proceed- ing complete the picture. The docket-visibility rec- ord shows South Carolina C-Track public searches, run with closed cases both included and excluded, in which Appellate Case No. 2026–000919 appears in no result set while Case No. 2026–000915, a pending ex- traordinary-writ matter filed the same day and in- volving a self-represented party, appears as pending. App.  62–65. After Petitioners identified that inconsistency to the Clerk’s office by email on May 15, 2026, citing Case No. 2026–000915 by name, the cited case disappeared from the public index between May 15 and May 19: direct queries for its number returned no records. The correspondence record pairs the Clerk of Court’s May 14, 2026 letter with Petitioners’ contem- poraneous account of a May 13, 2026 telephone call, presenting two mutually exclusive explanations of the docket status within 24 hours. App.  66–68. Petitioners filed a timely motion under Rule 59(e), SCRCP, in the circuit court on August 12, 2026. On August 14, 2026, the circuit court denied it by an elec- tronically filed Form 4 judgment stating that the court “is unable to discover any material fact or principle of law that has either been overlooked or disregarded.” The denial issued two days after the motion’s filing. That ruling and any subsequent appeal concern the sanctions and pleading holdings of the August 3 order; the filing architecture presented here lies outside that track.

I. The record itself proves the question (p. 24-25)

I. The record itself proves the question This petition asks the Court to look at four docu- ments. The first is the State’s filing rule. The SCE-File User Agreement states: “Only licensed South Carolina attorneys who are properly registered with AIS may electronically file documents using SCE-File.” App. 42.
The second is the image comparison demonstration. Exhibit E to the May 11, 2026 Notice places the court- file rendering of Petitioners’ photographic evidence beside the original: a monochrome page in which a smudge occupies the place where a person stands, and a color photograph in which the same person stands at the center of the frame. App.  53–56. The degradation is apparent to a layperson in seconds. The same page documents the parallel loss: counsel’s filing carries a machine-readable text layer, and Petitioners’ filing carries an image of text. App.  60. The third is the timing record. A motion for leave to amend sat 209 days without ruling. A federally grounded accommodation request sat 111 days with- out ruling. A represented party’s motion to relieve counsel, filed in the same case during the same period, was granted in five days. Each figure is calculated from filing dates in the record. The fourth is the judgment under review. Presented with that record in its original jurisdiction, the Supreme Court of South Carolina declined to act, explained the elapsed time by the county’s size and the ordinary requirements of judicial review, counted “more than forty motions, notices, and other documents” filed by the unrepresented parties, and closed with a warning about filing restrictions for “prolific or abusive filers.” App.  1–2. The order counts Petitioners’ filings and counts nothing on the other side of the ledger: no unruled motion, no elapsed day, no comparator. The record documented in this petition shows the state system’s denial of equal treatment, in sequence, ending in a merits ruling that only the degraded version of the evidence supports. The August 3, 2026 order found the Plaintiffs “depicted incidentally in a listing photograph, without being identified.” App.  30. On the original, an identifiable person stands at the center of her own home. App.  54–55.

III. The same architecture governed the opportunity to be heard (p. 27-29)

III. The same architecture governed the opportunity to be heard The access architecture under review extends beyond the intake of paper. It governs who may participate in the court’s work by electronic means, and on what terms. The record documents that dimension of the architecture, and it corroborates the question presented without requiring any separate holding. The opportunity to be heard “must be granted at a meaningful time and in a meaningful manner.” Armstrong v. Manzo, 380 U.  S. 545, 552 (1965). Due process attaches to state procedures that control the life of a claim, Logan v. Zimmerman Brush Co., 455 U.  S. 422, 428–433 (1982), and the timing of process is measured by the interests at stake, Mathews v. Eldridge, 424 U.  S. 319, 334–335 (1976). This Court held in Tennessee v. Lane, 541 U.  S. 509, 533–534 (2004), that Title II of the Americans with Disabilities Act, as applied to the fundamental right of access to the courts, enforces the Fourteenth Amendment. On January 30, 2026, Petitioner McNeil moved for two accommodations: electronic filing access and remote appearance. App.  69, 73–75. Both requests sought forms of electronic access that the State’s filing rule reserves to licensed attorneys. The motion sat 111 days without ruling, and the docket records its disposition on the day of the hearing it concerned, 118 days after filing. In the same period, the circuit court granted a represented party’s motion to relieve counsel in five days and honored a represented party’s informal email re- quest for remote appearance within four days. The record establishes when the court acted and for whom. The same measure appears after the judgment under review. On August 12, 2026, Petitioners filed a 23-page motion to alter or amend under Rule 59(e), SCRCP, supported by record citations. The circuit court denied it on August 14, 2026, by form judgment, 48 hours after filing. App.  78. A court that disposes of that motion in two days had left a motion for leave to amend unresolved for 209 days and a federally grounded accommodation request unresolved for 111. Decision speed in this record tracks one variable: whose filing it was. The judgment under review completes the corroboration. Presented with that record, the State’s highest court responded that the circuit court “requires time,” that “Charleston is a very large county,” and that Petitioners’ own filings “likely contributed to any delays.” App.  1–2. The same classification that governs the intake of evidence governed the allocation of the court’s attention: representation status predicted the fidelity of what the court received and the speed of what the court returned. Petitioners present that convergence as record confirmation of the question presented, and seek no holding beyond it.

V. This case is a clean vehicle (p. 31-32)

V. This case is a clean vehicle The question presented reduces to a pure question of law. The facts that carry it are documents: a user agreement, a docket, a paired image, and four orders. The record arrives complete for review as filed; the paired exhibit performs the only comparison the case needs, and it sits in the appendix. App.  53–56. The question was raised below and passed on. It entered the mandamus petition by name, with day counts and the five-day comparator. It entered the proceeding again through the May 11, 2026 Supplement, under a heading reading “The Fourteenth Amendment Significance of the Current Status Rec- ord,” and through the demonstration on the underly- ing docket. The May 21, 2026 order resolved the proceeding with stated reasons. App.  1–3. See pp. 9–11, supra. The judgment stands final under 28 U.  S.  C. § 1257(a). The original-jurisdiction proceeding is complete. The pending state track reviews the trial court’s sanctions and pleading rulings; the court system’s filing architecture sits outside that review, and only this Court reaches it. See supra, Jurisdiction. The respondent is the appropriate party. The classification under review belongs to the court system itself. The private defendants in the underlying action hold no stake in the filing rule and are not parties here. The question arrives unentangled with any private dispute. Finally, the record insulates the question from the discount ordinarily applied to self-represented filings. Every factual claim in the petition travels with a quoted record string or a reproduced document. A reader inclined to discount the filing because of who filed it confronts, in the appendix, the precise mechanism by which such discounting becomes self- executing: the State’s own intake process rendered these litigants’ evidence less legible than their opponents’ evidence before any human judgment reached it.

Conclusion (p. 33-33)

CONCLUSION
The petition for a writ of certiorari should be granted. James C. McNeil Meaghan Poyer P.O. Box 30386 Charleston, SC 29417 (843) 818–3495 chris@thaut.io

AUGUST 2026 Pro Se Petitioners

Appendix A - South Carolina Supreme Court Order (p. 37-39)

Petitioners have filed a pro se petition for a writ of mandamus asking this Court to direct the circuit court in Charleston to rule on (1) their motion to file a second amended complaint filed on October 24, 2025; (2) their motion for ADA accommodations filed on Jan- uary 30, 2026; and (3) their “Omnibus” motion filed on February 24, 2026. Because the circuit court has scheduled a hearing on Petitioners’ motions for May 28, 2026, we decline to entertain this matter in this Court’s original jurisdiction. See Rule 245, SCACR, and Key v. Currie, 305 S.  C. 115, 406 S.  E.  2d 356 (1991). However, we also take this opportunity to caution Petitioners that the circuit court requires time to review and consider individual motions and any accompanying materials prior to issuing a dispositive ruling. Furthermore, Charleston is a very large county, and Petitioners’ case is one of many pending before that court. The very fact that the circuit court has scheduled a hearing on Petitioners’ motions demonstrates that the circuit court is not ignoring Petitioners’ filings. Accordingly, seeking a writ of mandamus before this Court was unnecessary. While we understand any litigants’ concerns about the process, Petitioners are further cautioned that their excessive filings likely contributed to any delays in the case. Our review of the underlying case in the Charleston County public index indicates that Petitioners have filed more than forty motions, notices, and other documents during the eight-month time frame that the case has been pending. While Petitioners’ filings in the underlying case may not yet rise to the level of abusive, Petitioners are warned that this Court and the circuit court have the power to establish filing restrictions in the event that either court determines a litigant is a prolific or abusive filer.

Appendix B - August 3, 2026 Dismissal Order (p. 58-67)

As an additional sanction, I find and conclude that Plaintiffs Motions for Leave to File Second Amended Complaint are DENIED. In considering the equity of imposing this sanction, I have considered the allegations of the Proposed Second Amended Complaint. I find that, even in the absence of sanctionable conduct, the proposed amendment would likely be futile. The proposed claim for Negligence/ Statutory Negligence (Habitability, Care) fails based on the same analysis considered viewing the allegations of the Amended Complaint. The Plaintiffs seek to allege “Negligent “Listing/Privacy Safeguards” and, separately, “Invasion of Privacy. South Carolina recognizes three separate and distinct causes of action for invasion of privacy: 1) wrongful appropriation of personality; 2) wrongful publicizing of private affairs; and 3) wrongful intrusion into private affairs. Swinton Creek Nursery v. Edisto Farm Credit, 334 S.  C. 469, 514 S.  E.  2d 126 (1999). Based upon the allegations of the Proposed Second Amended Complaint, allegations such as the Plaintiffs being depicted incidentally in a listing photograph, without being identified, do not rise to the level of a cognizable claim. The Proposed Second Amended Complaint would seek relief based upon “Declaratory Judgment: Single Business Enterprise, Alter-Ego (Veil-Piercing) and, in the alternative, Joint Venture/Agency.” Without valid independent causes of action, these causes of action would be futile. Likewise, without a stand-alone cause of action for negligence, there is no cognizable claim for “Negligent Hiring, Retention, and Supervision (Against Charles S. Altman Individually).” This Court likewise finds no valid cause of action has been asserted for the proposed “Equitable & Injunctive Remedies” or violation of the South Carolina Unfair Trade Practices Act (SCUTPA). This Court has not considered these proposed claims in the light of a 12(b)(6) analysis. Rather, I have considered them to determine if there is prevented any real, legitimate or viable claim presented. Again, even if some semblance of a claim exists under any existing or proposed cause of action, this Court ultimately finds the merit and value of any such claim to be far outweighed by the abusive conduct, frivolous action, expense and harm caused by the Plaintiffs in the manner they have conducted this litigation. This Court determines that the interests of justice, order of the court and rights of the litigants are best served by bringing this litigation to an end, fully and finally, as a sanction. I find that this result is more likely to deter such conduct in the future and find that additional time, expense and resources necessary to deter- mine and assess appropriate attorneys’ fees, which ultimately may not be recovered, result in the greater benefit and orderly administration of justice being the full conclusion of this matter. Accordingly, based on the foregoing, this action is
DISMISSED FULLY, IN ITS ENTIRETY, WITH
PREJUDICE.

Appendix D - SCE-File User Agreement Access Rule (p. 78-78)

South Carolina Courts’ Electronic Filing System (SCE-File) User Agreement This User Agreement serves as your agreement with the South Carolina Judicial Department for the pur- pose of electronically filing court documents. For li- censed South Carolina attorneys, the User Agreement will remain in effect as long as you are properly registered with the South Carolina Attorney Information System (AIS). NOTE: Pro Hac Vice attorneys are prohibited from registering to use SCE-File. Only licensed South Carolina attorneys who are properly registered with AIS may electronically file documents using SCE-File.

Appendix J - Supplemental Motion for ADA Accommodation (p. 108-111)

REQUESTED ADA ACCOMMODATIONS
In light of the severe PTSD-related symptoms and functional limitations described above, which substantially limit Mr. McNeil’s major life activities, including sleep, concentration, safe driving, and his ability to manage in-person court obligations, and which are currently documented through validated self-report instruments (including a PCL-5 score of 76/80 in the severe range) and contemporaneous written records—Plaintiffs respectfully request the following reasonable modifications to court procedures un- der Title II of the ADA, so that Mr. McNeil can meaningfully access and participate in this litigation while he seeks formal medical evaluation. e-filing access Co-Plaintiff Meaghan Poyer is not disabled, but as a full-time employee she is only intermittently able to leave work during courthouse business hours, and cannot reliably serve as the sole physical conduit for preserving both Plaintiffs’ rights through hand-filings.
1. Electronic Filing Access for Disabled Plaintiff
(and Joint Use by Co-Plaintiff). That, as a reasonable modification of current procedures under Title II of the ADA, the Court authorize Plaintiff James C. McNeil, as a pro se litigant experiencing severe PTSD-related limitations that he reasonably believes qualify as a disabil- ity under the ADA, to register for and use the Court’s existing electronic filing system in this case, so that he can file pleadings, motions, and exhibits, and receive notices and orders elec- tronically. Because Mr. McNeil and Ms. Poyer are joint pro se plaintiffs who ordinarily file and sign pleadings together, Plaintiffs further request that these electronic-filing credentials be available for use in connection with filings made in both Plaintiffs’ names, rather than re- quiring separate, repeated physical trips by Ms. Poyer solely to compensate for Mr. McNeil’s disability-related limitations.
2. Alternative Only If Full E-Filing Access Is Denied (Email Treated as Filed Upon Receipt). If, and only if, the Court determines that granting full electronic-filing credentials to a pro se litigant is not feasible in this forum, Plaintiffs request, as a functionally equivalent accommodation, an order providing that: PDFs of signed pleadings, motions, and exhibits sent from Mr. McNeil’s email address to a designated Clerk of Court email address in this case will be deemed filed as of the timestamp of receipt shown on the Clerk’s server; and The Clerk will promptly docket those filings in the case management system and return a clock-stamped PDF confirmation to Plaintiffs by email. Remote Appearance Option for Non-Eviden- tiary Hearings. That, for status conferences and motion hearings that do not involve live witness testimony:
1. Plaintiffs may appear by Zoom or comparable
remote video platform if they give at least 24 hours’ notice of their intent to do so; and
2. No party shall object to remote appearance
solely on the ground that Plaintiffs are pro se or that in-person attendance is customary, where Plaintiffs have documented a PTSD-re- lated functional limitation on in-person con- frontation.

Appendix K - August 14, 2026 Form 4 Judgment (p. 113-115)

IT IS ORDERED AND ADJUDGED: ☐ See attached order (formal order to follow) ☒ Statement of Judgment by the Court: This matter is before the Court on Plaintiff’s Motion for Reconsideration pursuant to Rule 59(e) SCRCP, which was timely filed on August 12, 2026. The Motion asks this Court to alter, amend, or reconsider its ORDER, entered August 3, 2026. After reviewing the applicable law and considering arguments raised in the Motion, the court is unable to discover any material fact or principle of law that has either been overlooked or disregarded and further finds no error of law or fact not appropriately considered. Therefore, the Motion to Alter, Amend, or Reconsider is respectfully DENIED.