After denial of her motion to suppress, defendant was convicted in the Municipal Court, Town of Sullivan’s Island, of violating town’s disorderly conduct ordinance for loudly berating her ride-share driver with profanity and xenophobic epithets on public street in residential area at almost 2:00 a.m.
Defendant appealed. The Circuit Court affirmed. Defendant appealed.
The Supreme Court held that:
- Ordinance was a content-neutral time, place, and manner restriction that did not violate free speech rights as applied;
- Ordinance was not unconstitutionally vague under Due Process Clause; and
- State established sufficient chain of custody to admit video from ride-share driver’s dash camera.