; Meyer v. McGowan, C/A No. 2:16-00777-RMG, 2018 WL 4462367, at *5 (D.S.C. Sept. 18, 2018) (same).
"[W]hen a Sheriff's deputy uses 'force greater than is reasonably necessary under the circumstances' the governmental agency may be liable for battery." Id. (citing Roberts v. City of Forest Acres, 902 F. Supp. 662, 671-72 & n. 2 (D.S.C.1995); see also Newkirk v. Enzor, 240 F. Supp. 3d 426, 435-37 (D.S.C. 2017) (holding ยง 15-78-60(17) did not automatically bar the plaintiff's SCTCA claims for assault, battery, malicious prosecution, and false imprisonment simply because they were intentional torts, and noting "each tort [the plaintiff] alleges could be committed without actual malice or intent to harm"); Simmons v. Charleston Cty. Sheriff's Office, C/A No. 2:19-1754-BHH, 2019 WL 5387911, at *1 (D.S.C. Oct. 22, 2019) ("The governmental agency, in this case CCSO, may be liable for the assault and battery."); Meyer v. McGowan, C/A No. 2:16-00777-RMG, 2018 WL 4462367, at *5 (D.S.C. Sept. 18, 2018) (same). Defendants cite two cases that appear to hold otherwise.