RANDALL WILLIAMS, Personal Representative of the Estates of Shanice R. Dantzler-Williams v. Charleston County Sheriff’s Office

UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 24-1238
RANDALL WILLIAMS, Personal Representative of the Estates of Shanice R.
Dantzler-Williams and Miranda R. Dantzler-Williams; BETTY SIMMONS,
Personal Representative of the Estate of Stephanie Dantzler,
Plaintiffs – Appellants,
v.
CHARLESTON COUNTY SHERIFF’S OFFICE,
Defendant – Appellee,
and
CHARLESTON COUNTY; EMILY PELLETIER; CLINTON SACKS,
Defendants.
On Remand from the Supreme Court of the United States. (S. Ct. No. 25-640)
Submitted: November 14, 2024 Decided: July 15, 2026
Before HARRIS, HEYTENS, and BERNER, Circuit Judges.
Affirmed by unpublished per curiam opinion.
ON BRIEF: Richard A. Hricik, LAW OFFICES OF RICHARD A. HRICIK, PA, Mount
Pleasant, South Carolina; Clifford Bush, III, THE LAW OFFICE OF CLIFFORD BUSH,
III, LLC, Beaufort, South Carolina, for Appellants. Elloree A. Ganes, Evan M. Sobocinski,

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Deborah Harrison Sheffield, HOOD LAW FIRM, LLC, Charleston, South Carolina, for
Appellee.
Unpublished opinions are not binding precedent in this circuit.

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PER CURIAM:
The Supreme Court vacated our previous decision and directed us to reconsider this
case in light of Galette v. New Jersey Transit Corp., 146 S. Ct. 854 (2026). Williams v.
Charleston Cnty. Sheriff’s Off., 2026 WL 795252 (U.S. Mar. 23, 2026). It is well-settled
that such orders do not necessarily indicate that the vacated decision was incorrect or needs
to be revised. United States v. Canada, 123 F.4th 159, 160 (4th Cir. 2024). We have
carefully reviewed Galette and our previous decision in this case and conclude they are
fully consistent. In particular, Galette addressed the implications of the corporate form for
the Eleventh Amendment analysis, and its central holding – that the New Jersey Transit
Corporation is not an arm of the state entitled to Eleventh Amendment immunity because
it is “a corporation with the traditional corporate powers to sue and be sued, hold property,
make contracts, and incur debt,” 146 S. Ct. at 868 – does not supersede our court’s
controlling precedent or directly bear on this case. We therefore re-adopt and re-issue our
previous decision in this case.
* * *
This appeal arises from a heartbreaking accident. On Mother’s Day in 2022,
Stephanie Dantzler and her adult daughters, Shanice and Miranda Dantzler-Williams, were
driving in Charleston County, South Carolina. Nearby, two Charleston County sheriffs,
Deputies Emily Pelletier and Clinton Sacks, were responding to a non-emergency report
of a stalled vehicle. Without activating her car’s emergency lights or sirens, Pelletier sped
through a stop sign, crossed multiple lanes of traffic, and struck the women’s car. Dantzler
and her daughters suffered catastrophic injuries, and died shortly after.

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The plaintiffs in this action are Randall Williams, representing the estate of his
daughters Shanice and Miranda, and Betty Simmons, representing the estate of her
daughter Dantzler. In their complaint, the plaintiffs brought multiple claims against
Deputies Pelletier and Sacks, in both their individual and official capacities; Charleston
County; and the Charleston County Sheriff’s Office. This appeal involves only some of
the plaintiffs’ claims against one of the defendants, the Charleston County Sheriff’s
Office.1
The County Sheriff’s Office filed a motion to dismiss the plaintiffs’ “Monell” claims
against it, in which the plaintiffs sought to hold the Sheriff’s Office liable under 42 U.S.C.
§ 1983 as a municipality. See Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658
(1978). The Sheriff’s Office invoked the state’s Eleventh Amendment immunity from suit,
contending that is not a municipality but instead an “arm of the state” for purposes of the
Eleventh Amendment.
The district court agreed and dismissed the § 1983 claims against the Sheriff’s
Office. Williams v. Pelletier, 2023 WL 8627812, at *5 (D.S.C. Dec. 13, 2023). In Cromer
v. Brown, 88 F.3d 1315 (4th Cir. 1996), as the district court explained, the Fourth Circuit
had already considered the Eleventh Amendment status of South Carolina’s county
sheriff’s offices, and determined that they are agents of the state protected from suit by
1 The plaintiffs’ many other claims will proceed before the district court, and we of
course express no view as to their merits. We may review the district court’s ruling as to
this subset of the plaintiffs’ claims because the district court certified its order as a final
judgment under Rule 54(b) of the Federal Rules of Civil Procedure. See Williams v.
Pelletier, 2024 WL 1075444, at *1 (D.S.C. Mar. 12, 2024).

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Eleventh Amendment immunity. See Williams, 2023 WL 8627812, at *3. The court
rejected the plaintiffs’ argument that an analysis under the factors laid out in an earlier
Fourth Circuit case pointed in a different direction, indicating that the Sheriff’s Office
should be treated as a municipality rather than a state entity. See id. at *5 (discussing Ram
Ditta ex rel. Ram Ditta v. Md. Nat’l Cap. Park & Plan. Comm’n, 822 F.2d 456 (4th Cir.
1987)). Those factors, the court reasoned, were incorporated into the Fourth Circuit’s
subsequent decision in Cromer, and that decision remained “controlling precedent” that
foreclosed the plaintiffs’ position. Id.
We review the district court’s judgment de novo, see Hutto v. S.C. Ret. Sys., 773
F.3d 536, 542 (4th Cir. 2014), and we affirm for substantially the same reasons given by
the district court.
The Eleventh Amendment immunizes “unconsenting State[s]” from suit in federal
court, and its protections extend to “agencies that may be properly characterized as ‘arm[s]
of the State.’” Harter v. Vernon, 101 F.3d 334, 337 (4th Cir. 1996) (quoting Mt. Healthy
City Bd. of Educ. v. Doyle, 429 U.S. 274, 280 (1977)). To determine whether an entity like
the County Sheriff’s Office is an arm of the state entitled to Eleventh Amendment
immunity, this court employs a well-established four-factor balancing test. See Ram Ditta,
822 F.2d at 457–58. And in Cromer, we held, after considering the “factors relevant to the
immunity analysis,” that a South Carolina county sheriff is an “arm of the state” protected
from suit by the Eleventh Amendment. 88 F.3d at 1332. That is enough to resolve this
case.

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On appeal, as before the district court, the plaintiffs argue that an independent
analysis of the Ram Ditta factors would show that the County Sheriff’s Office is not a state
agency for these purposes, and that Cromer should not be followed because it pays
insufficient attention to those factors. It is true that Cromer’s analysis is brief and does not
expressly address Ram Ditta, instead invoking generally the “relevant factors.” But
Cromer is directly on point, and its binding effect does not turn on the length or even the
persuasiveness of its reasoning. Cromer has not been abrogated by statute or superseded
by an en banc or Supreme Court decision, which means that we – like the district court –
are bound to follow it. See United States v. Ruhe, 191 F.3d 376, 388 (4th Cir. 1999) (setting
out general rule that a “simple panel” is bound by prior Fourth Circuit precedent “absent
contrary law from an en banc or Supreme Court decision”); Payne v. Taslimi, 998 F.3d
648, 654 & n.2 (4th Cir. 2021) (describing duty to follow prior circuit precedent as
“mechanical mandate”).2
Accordingly, we affirm the judgment of the district court.
AFFIRMED
2 In support of their argument under the Ram Ditta factors, the plaintiffs have asked
us to take judicial notice of certain publicly available facts about the fiscal workings of
Charleston County and the State of South Carolina Insurance Reserve Fund, through which
the County Sheriff’s Office is insured. Because we now hold that we are bound by Cromer
and not at liberty to undertake a new and independent analysis, we deny that motion as
moot.

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