State v. Bailey

Anthony Bailey appeals his conviction for threatening the life of a public official, arguing the circuit court erred in finding a mental health professional employed by the South Carolina Department of Mental Health (the Department) was a public official, rather than a public employee, under section 16-3-1040 of the South Carolina Code (2015). We reverse.

FACTS/PROCEDURAL HISTORY

This appeal arises out of an incident that occurred on August 28, 2013, at the Al Cannon Detention Center located in Charleston County, South Carolina. Bailey, who suffers from bipolar disorder, was being held in the…