An Email Constitutes Written Notice For Purposes of Rule 203(b)(1), SCACR
In Wells Fargo Bank, N.A. v. Fallon Properties South Carolina, LLC, No. 2015-000157 (S.C. App. Aug. 26, 2015) (Shearouse Adv. Sh. No. 33), the South Carolina Court of Appeals found that an email from a court with the order on appeal as an attachment constitutes written notice of entry of the order under Rule 203(b)(1) of the South Carolina Rules of Appellate Procedure. In Wells, the court noted that the email was sent from the court and included a copy of the signed and clocked order. Moreover, the court noted that the Rules contemplate service by email. Therefore, the court concluded that the time for filing a notice of appeal began to run on the date of receipt of the email by counsel and not on the date counsel received a printed copy of the order by regular U.S. mail.