Johnathan Daniels v. City of Cayce (2)

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 Court of Appeals

Johnathan Daniels, Appellant,

v.

City of Cayce, Respondent.

Appellate Case No. 2022-001437

Appeal From Lexington County
Robert E. Hood, Circuit Court Judge

Unpublished Opinion No. 2025-UP-330
Submitted September 1, 2025 – Filed October 1, 2025

AFFIRMED

Johnathan Daniels, of Columbia, pro se.

Danny Calvert Crowe, of Garfield Spreeuwers Law
Group, LLC, of Columbia, for Respondent.

PER CURIAM: Johnathan Daniels appeals his guilty plea and fine of $155 for
driving without a license and the dismissed charge of operating an unregistered
vehicle. On appeal, Daniels argues the municipal court erred in accepting his
guilty plea because: (1) the enforcement of the driver's license and vehicle
registration statutes1 violated his free exercise of religion, (2) the municipal court
lacked subject matter jurisdiction, (3) the guilty plea transcript was prejudicial, (4)
his guilty plea was involuntary, (5) the municipal court abused its discretion by
denying his motion to compel discovery, and (6) the prosecution was barred by
collateral and judicial estoppel. We affirm pursuant to Rule 220(b), SCACR.

First, we hold the circuit court did not err in finding Daniels knowingly and
voluntarily pled guilty. See State v. Goodwin, 351 S.C. 105, 110, 567 S.E.2d 912,
914 (Ct. App. 2002) ("In criminal cases, [the appellate] court sits to review errors
of law only, and [is] bound by the trial judge's factual findings unless they are
clearly erroneous."). The record before this court shows Daniels was aware of his
constitutional rights, the municipal court advised him of the potential sentences for
driving without a license and failing to register his vehicle, Daniels acknowledged
he understood the terms of the plea negotiations, and he stated he was not
threatened or coerced to plead guilty. Daniels also admitted committing the crimes
but averred his religious beliefs prevented him from obtaining a driver's license
and registering his vehicle. Accordingly, Daniels's guilty plea was voluntary
because he acknowledged the penalties, admitted committing the crimes, and
stated his plea was not induced by threat or coercion. See Roddy v. State, 339 S.C.
29, 33, 528 S.E.2d 418, 421 (2000) ("To find a guilty plea is voluntarily and
knowingly entered into, the record must establish the defendant had a full
understanding of the consequences of his plea and the charges against him."); State
v. Lambert, 266 S.C. 574, 578, 225 S.E.2d 340, 342 (1976) ("If the record shows
that the plea was so entered, then it is not silent as to the waiver of his
constitutional rights."); id. at 579, 225 S.E.2d at 342 ("[A]n enumeration of
specific rights waived is not required where the record otherwise reveals
affirmative awareness of the consequences of a guilty plea."); id. at 580, 225
S.E.2d at 342 ("If the record reflects . . . that the trial court has assured itself that
the plea was voluntary and intelligently entered with full knowledge of the nature
of the offense, then lack of precise language in the record expressing these
considerations is not of itself a valid reason for reversal."); Rayford v. State, 314
S.C. 46, 48, 443 S.E.2d 805, 806 (1994) (finding the petitioner's guilty plea was
voluntarily made when he admitted committing the crimes, acknowledged the
potential sentences, and stated his plea was not induced by promises).

Second, we hold the South Carolina Religious Freedom Act 2 (SCRFA) provides a
defense related to religious freedom, not grounds for a jurisdictional challenge.

1
S.C. Code Ann. § 56-1-20 (Supp. 2024) and S.C. Code Ann. § 56-3-110 (2018).
2
S.C. Code Ann. § 1-32-10 to -60 (2005).
Therefore, Daniels could and did waive his SCRFA argument when he pled guilty.
See Goodwin, 351 S.C. at 110, 567 S.E.2d at 914 ("In criminal cases, [the
appellate] court sits to review errors of law only, and [is] bound by the trial judge's
factual findings unless they are clearly erroneous."); Whetsell v. State, 276 S.C.
295, 297, 277 S.E.2d 891, 892 (1981) ("The general rule is that guilty pleas, freely
and voluntarily entered, act as a waiver of all non-jurisdictional defects and
defenses, including the claims of a violation of a constitutional right prior to the
plea."); S.C. Code Ann. § 1-32-50 (2005) ("If a person's exercise of religion has
been burdened in violation of this chapter, the person may assert the violation as a
claim or defense in a judicial proceeding."); cf. State v. Sims, 423 S.C. 397, 402,
814 S.E.2d 632, 634 (Ct. App. 2018) (explaining a jurisdictional defect did not
exist because the defendant did not establish his entitlement to immunity from
prosecution under the Protection of Persons and Property Act and thus, his guilty
plea waived his immunity claim).

Finally, we hold Daniels waived his remaining issues on appeal when he pled
guilty. See Whetsell, 276 S.C. at 297, 277 S.E.2d at 892 ("The general rule is that
guilty pleas, freely and voluntarily entered, act as a waiver of all non-jurisdictional
defects and defenses, including the claims of a violation of a constitutional right
prior to the plea.").

AFFIRMED. 3

MCDONALD, HEWITT, and TURNER, JJ., concur.

3
We decide this case without oral argument pursuant to Rule 215, SCACR.