Jump To

Top Caption Syllabus Combined Opinion

Support FLP

CourtListener is a project of Free
Law Project, a federally-recognized 501(c)(3) non-profit. Members help support our work and get special access to features.

Please become a member today.

Join Free.law Now

March 18, 2026 Get Citation Alerts Download PDF Add Note

In the Matter of Judge Curtis G. Clark, Former Abbeville County Master-in-Equity

Supreme Court of South Carolina

• Citations: None known

• Docket Number: 2025-002528

• Opinion

• Authorities (1)

• Cited By (0)

• Summaries (0)

• Similar Cases (8.1K)

• PDF

Syllabus

In this judicial disciplinary matter, the Court imposes a public reprimand.

Combined Opinion

THE STATE OF SOUTH CAROLINA
In The Supreme Court

In the Matter of Judge Curtis G. Clark, Former Abbeville
County Master-in-Equity, Respondent.
Appellate Case No. 2025-002528

Opinion No. 28322
Submitted February 20, 2026 – Filed March 18, 2026

PUBLIC REPRIMAND

Disciplinary Counsel William M. Blitch, Jr., and
Assistant Disciplinary Counsel Kristina Jones Catoe,
both of Columbia, for the Office of Disciplinary Counsel.

Harvey M. Watson, III, of Ballard & Watson, Attorneys
at Law, of West Columbia, for Respondent.

PER CURIAM: In this judicial disciplinary matter, Respondent and the Office
of Disciplinary Counsel (ODC) have entered into an Agreement for Discipline by
Consent (Agreement) pursuant to Rule 21, RJDE, Rule 502, SCACR. In the
Agreement, Respondent admits misconduct, agrees to pay costs, and consents to
the imposition of a letter of caution, a confidential admonition, or a public
reprimand. Respondent also agrees never to seek nor accept a judicial office in
South Carolina in the future. We accept the Agreement and publicly reprimand
Respondent, the most severe sanction we are able to impose under these
circumstances.

I.

Respondent served as a special referee in Abbeville County from 1999 to 2001,
before serving as a master-in-equity in Abbeville County from 2001 to 2019.
Respondent also served as a probate court judge and special referee in Greenwood
County beginning in 1987. As a special referee and master-in-equity, Respondent
was responsible for conducting auctions for property previously subject to
foreclosure proceedings. In April 2022, a local newspaper published an
investigative article regarding Respondent presiding over auctions that resulted in
Respondent deeding properties to his family members after their bids were the
highest at the auction. This article also mentioned instances in which Respondent's
family members were hired by a third-party company to bid on property for the
company. On April 11, 2022, former Chief Justice Beatty issued an administrative
order indefinitely barring Respondent from acting or serving as a special referee in
any foreclosure matter in this state.1

A third-party company (Company) provides bidding agents for auctions of
foreclosed property in locations throughout South Carolina, including those in
which Respondent formerly presided. Due to the large volume of auctions in
certain locations, Company would contact Respondent's office and ask for
assistance with obtaining an agent to bid at auctions. Respondent would provide
names of individuals, including his wife and other family members, as potential
bidding agents. Company provided the bidding instructions to the bidding agents
and compensated the bidding agents a flat fee negotiated between the agent and the
Company. On numerous occasions, a member of Respondent's family served as a
bidding agent for a property that was sold at an auction Respondent conducted.

In 2015, Respondent and his family became aware of two pieces of property near
Respondent's home were facing potential foreclosure. Property One was a 33-acre
tract of land, and Property Two was a 2.79-acre tract that included a home.
Respondent and his family discussed the properties prior to the foreclosure
proceedings and auctions because Respondent's son and daughter expressed
interest in purchasing the properties. Respondent's son expressed interest in
Property One, which came up for auction in 2016. Respondent conducted both the
hearing that resulted in the foreclosure of that property and the auction in which his
son was the highest bidder on the property. Respondent then provided his son with
the necessary funds to satisfy the bid. 2 Between the hearing and the auction, there

1
In re Special Referee Appointments, S.C. Sup. Ct. Order dated Apr. 11, 2022.
(Appellate Case No. 2022-000468).
2
In his initial response to the Notice of Investigation on May 31, 2022, Respondent
represented that different circumstances surrounded this exchange of funds.
However, in an April 17, 2023 response to ODC's request for additional
information, Respondent admitted providing the funds to his son for the purchase
of Property One.
was a period of at least three weeks in which another special referee could have
been designated to conduct the auction of Property One. Respondent maintains
that he was not involved in any pre-auction negotiations regarding Property One.
Shortly after purchasing Property One, Respondent's son decided that he did not
want the property due to his business issues. However, Respondent's son kept
Property One for a period of time while awaiting foreclosure on Property Two,
which Respondent's daughter wished to purchase.

Prior to the initiation of foreclosure proceedings on Property Two, Respondent and
his daughter attempted to negotiate a short sale, but these attempts were not
successful. Upon notice that Respondent had been appointed to serve as special
referee for the foreclosure proceedings related to Property Two, Respondent
removed himself as the special referee because of his involvement in the prior
negotiations. Another lawyer served as special referee for the foreclosure on
Property Two and eventually issued an order of foreclosure. The Greenwood
County Clerk of Court conducted the subsequent sale of Property Two by auction.
Respondent's daughter prevailed as the highest bidder at the auction in 2017.
Respondent provided his daughter with the necessary funds to satisfy the bid. In
2018, Respondent's daughter repaid him for the monies he expended for the
original purchase through a cash-out loan that was secured by Property Two.

Thereafter, Respondent's daughter attempted to obtain driveway access to Property
Two. After consulting with the Greenwood County Planning and Zoning
Department, Respondent's family determined that the best method for Respondent's
daughter to obtain the necessary access was for Respondent's son to deed Property
One to Respondent's daughter. Respondent's daughter subsequently deeded
Property One to Respondent to compensate Respondent for the monies he provided
his son for the original purchase of Property One. Respondent then granted a
private easement across Property One for his daughter to access Property Two.

Additionally, Respondent's wife bid on numerous properties auctioned by
Respondent and other special referees, both as a bidding agent for Company and in
her personal capacity. In her personal capacity, Respondent's wife also had
arrangements with other partners and other third parties who bid on property and
assigned the bid or a portion of the bid to her. After being deeded the purchased
properties, Respondent's wife rented out many of them and deposited the proceeds
into a bank account jointly held with Respondent. Respondent represents that his
name was on the account for administrative purposes only; however, Respondent
and his wife reported all income from the rental properties yearly on their joint
income tax return. Respondent represents that not all rental income-generating
properties owned by he and his wife were obtained via judicial sale. However,
some of the properties auctioned by Respondent as a special referee were
purchased by his wife and generated rental income.

During the course of Respondent's November 2012 screening by the Judicial Merit
Selection Commission, Respondent was questioned about a concern received by
the Commission about Respondent's wife bidding on judicial sales over which
Respondent presided. Respondent responded to the concern from an undisclosed
party by discussing a particular circumstance where Respondent's wife had bid on
a property in Laurens County on behalf of Company. Respondent states a local
attorney observed the bidding and expressed concern about Respondent's wife's
role. Respondent did not disclose to the Commission that his wife also bid
individually on judicial sales over which he presided. Respondent represents that
he did not mention this because there was only one circumstance in which an
attorney expressed a concern about Respondent's wife's role in bidding on
properties, and Respondent assumed the Commission's question referenced only
that particular incident, which occurred outside of Abbeville and Greenwood
counties. Respondent represents that his response was limited at that time to the
incident and that he considered his answer complete at the time it was made.

Respondent further represents that he is approaching retirement and has reduced
his practice of law to engage with legal matters only about three days per week.

II.

Respondent admits that his conduct violated the following provisions of the Code
of Judicial Conduct, Rule 501, SCACR: Canon 1 (requiring a judge to uphold the
integrity of the judiciary); Canon 1A (requiring a judge to maintain and personally
observe high standards of conduct); Canon 2 (requiring a judge to avoid
impropriety and the appearance of impropriety in all activities); Canon 2A
(requiring a judge to act at all times in a manner that promotes public confidence in
the integrity of the judiciary); and Canon 4D(1)(a) (forbidding a judge from
engaging in financial and business dealings that may reasonably be perceived to
exploit the judge's judicial position).

Respondent further admits his misconduct is a ground for discipline under Rule
7(a)(1), RJDE, Rule 502, SCACR (providing a violation of the Code of Judicial
Conduct is a ground for discipline). As a condition of discipline, Respondent
agrees not to seek or accept appointment as a special referee in South Carolina in
the future. 3

In his affidavit in mitigation, Respondent emphasizes his almost forty years of
service as a probate judge, master-in-equity, and special referee. Respondent also
details his other service to the bench and the Bar, including service on the Probate
Judges Advisory Committee, as course planner for the equity portion of the former
Bridge the Gap program for newly admitted lawyers, and as an editor of the first
edition of the South Carolina Foreclosure Law Manual. Respondent expresses
remorse, notes his cooperation with the ODC investigation, and emphasizes that
neither he nor any of his friends or family members "ever acted upon any non-
public information in connection with an auction." However, Respondent
acknowledges how third-party observers might have reasonably thought otherwise
and how that would undermine public confidence in the integrity of the
proceedings. Respondent also notes his lack of prior disciplinary history and four
character letters attached to his affidavit, all of which vouch for him personally and
professionally. Respondent urges this Court to impose a nonpublic sanction
because he intends to retire soon and there is therefore little need to protect the
public or prompt him to conform his future conduct with the relevant ethical
obligations.

III.

Because Respondent no longer serves in any judicial capacity and because he has
agreed not to seek or accept appointment as a special referee in South Carolina in
the future, we accept the Agreement and issue a public reprimand. This is the
strongest punishment we can give Respondent, given the fact that he no longer
holds judicial office. See In re Gravely, 321 S.C. 235, 467 S.E.2d 924 (1996) ("A
public reprimand is the most severe sanction that can be imposed when the
respondent no longer holds judicial office.") Accordingly, Respondent is hereby
publicly reprimanded for his misconduct. Within thirty days, Respondent shall pay
the costs incurred in the investigation and prosecution of this matter by ODC and
the Commission on Judicial Conduct.

3
Respondent remains subject to this Court's April 11, 2022 administrative order
indefinitely prohibiting him from serving as a special referee anywhere in this
state.
PUBLIC REPRIMAND.

KITTREDGE, C.J., FEW, JAMES, HILL and VERDIN, JJ., concur.