Unlike Batson, several significant witnesses, including Respondent, minor Appellants, and Roe, have already been deposed. Testimony elicited during those depositions created at least a mere scintilla of evidence as it relates to whether Respondent either knew or should have known that Mr. Bibby posed a specific threat of harm to the children that Respondent invited into her home. See Bass v. Gopal, Inc., 395 S.C. 129, 134, 716 S.E.2d 910, 912 (2011) (citing Hancock v. Mid-South Mgmt. Co., Inc., 381 S.C. 326, 330, 673 S.E.2d 801, 803 (2009)) (“In a negligence case, where the burden of proof is a preponderance of the evidence standard, the non-moving party must only submit a mere scintilla of evidence to withstand a motion for summary judgment.”); Bishop, 331 S.C. at 88, 502 S.E.2d at 82 (<HOLDING>). Although the circuit court placed emphasis on
holding that common law duty to warn arises when a person being released from custody has made a specific threat of harm directed at a specific individual holding that chilling effect claim must still be rooted in specific present objective harm or a threat of specific future harm to convey standing holding that a threat to harm another person is a crime of violence holding all that is required to impose a duty to warn is that the defendant knew or should have known of a specific threat made to harm a specific person holding that plaintiffs who alleged a subjective chill of their first amendment rights failed to establish specific present objective harm or a threat of specific future harm