Supreme Court Appoints Receiver for Attorney Mark Maniscalco

SC Court Orders

Filed February 12th, 2026

Detected March 18th, 2026

Summary

The Supreme Court of South Carolina has appointed a receiver for attorney Mark Maniscalco due to his transfer to incapacity inactive status. John Earle Tyler, Esquire, is appointed to protect the interests of Mr. Maniscalco's clients by assuming responsibility for client files and financial accounts.

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What changed

The Supreme Court of South Carolina issued an order on February 12, 2026, appointing John Earle Tyler, Esquire, as Receiver for attorney Mark Lee Maniscalco. This action follows Mr. Maniscalco's transfer to incapacity inactive status. The Receiver is tasked with protecting the interests of Mr. Maniscalco's clients by taking control of client files, trust accounts, escrow accounts, and operating accounts. The order also serves as an injunction against Mr. Maniscalco withdrawing funds and notifies financial institutions and the postal service of the Receiver's authority.

Legal professionals in South Carolina should be aware of this order, particularly regarding the procedures for handling client files and accounts when an attorney is incapacitated. The Receiver's actions are governed by specific rules (Rule 31, RLDE, Rule 413, SCACR). While the Receiver can manage and disburse funds from the accounts to protect client interests, they are generally prohibited from practicing law. This order serves as official notice to banks and the postal service, preventing unauthorized access to the attorney's accounts and mail.

What to do next

Review Rule 31, RLDE, and Rule 413, SCACR, for procedures related to attorney incapacity and receivership.
Ensure any financial institutions holding attorney trust, escrow, or operating accounts are properly notified of this order if applicable.
Understand the scope of authority granted to the Receiver regarding client files and financial accounts.

Source document (simplified)

The Supreme Court of South Carolina In the Matter of Mark Lee Maniscalco, Respondent. Appellate Case No. 2026-000294 ORDER By order dated February 12, 2026, Respondent was transferred to incapacity inactive status pursuant to Rule 28, RLDE, Rule 413, SCACR. In light of this transfer, John Earle Tyler, Esquire, is hereby appointed as Receiver in this matter to protect the interests of Respondent's clients. IT IS ORDERED that Mr. Tyler shall assume responsibility for Respondent's client files, trust account(s), escrow account(s), operating account(s), and any other law office accounts Respondent may maintain. Mr. Tyler shall take action as required by Rule 31, RLDE, Rule 413, SCACR, to protect the interests of Respondent's clients. Except as authorized by Rule 31(d)(5), RLDE, Rule 413, SCACR, Mr. Tyler may not practice law in any federal, state, or local court, including the entry of an appearance in a court of this State or of the United States. Mr. Tyler may make disbursements from and close Respondent's trust account(s), escrow account(s), operating account(s), and any other law office accounts Respondent may maintain that are necessary to effectuate this appointment. This Order, when served on any bank or other financial institution maintaining trust, escrow and/or operating account(s) of Respondent, shall serve as an injunction to prevent Respondent from making withdrawals from the account(s) and shall further serve as notice to the bank or other financial institution that John Earle Tyler, Esquire, has been duly appointed by this Court. Finally, this Order, when served on any office of the United States Postal Service, shall serve as notice that John Earle Tyler, Esquire, has been duly appointed by this Court and has the authority to receive Respondent's mail and the authority to direct that Respondent's mail be delivered to Mr. Tyler's office.

s/ John W. Kittredge C.J. FOR THE COURT Columbia, South Carolina February 12, 2026