In Anderson v. South Carolina Department of Highways and Public Transportation, 322 S.C. 417, 420, 472 S.E.2d 253, 254 (1996), the Court addressed and rejected an "unusual application" of the "two issue" rule. Id. Anderson was injured in a fall on a sidewalk, and she sued the South Carolina Department of Highways and Public Transportation on a theory of negligence in maintaining the sidewalk. Anderson moved for a directed verdict as to liability, but the trial court deferred ruling on the motion. The case was submitted "to the jury on the issues of general negligence and contributory negligence, and the jury returned a general verdict for Highway Department." Id. at 419. The trial court then granted Anderson's directed verdict motion, ruling as a matter of law that the Highway Department was negligent in its maintenance of the sidewalk. The trial court granted a new trial since it could not determine "whether the jury reached its verdict for Highway Department on the basis of Anderson's failure to prove improper maintenance, Anderson's failure to prove proximate cause, or Highway Department's success in proving contributory negligence." Id. On appeal, the Court reversed the granting of the new trial, finding the jury verdict should have been sustained under the "two issue" rule. Anderson v. South Carolina Dep't of Hwys. & Pub. Transp., 317 S.C. 280, 282, 454 S.E.2d 353, 354-55 (Ct. App. 1995). The supreme court granted certiorari and affirmed in result, but rejected the application of the "two issue" rule. Anderson provides a thoughtful analysis of the appropriate application of the "two issue" rule. Of particular note is the court's discussion of the three reasons for rejecting the "two issue" rule in that case: Initially, the rule is utilized by courts on appeal, not trial courts. Secondly, the rule is a procedural tool for upholding, not reversing, decisions. Thirdly, the practical effects of the Court of Appeals' application of the "two issue" rule are undesirable. Such an application would discourage trial courts from correcting errors. Because the jury's general verdict could potentially be upheld anytime it was susceptible of two or more constructions, there would be no incentive for trial courts to correct errors, such as through the direction of a post-trial verdict. (Anderson v. South Carolina Dep't of Hwys. & Pub. Transp., 322 S.C. at 421, 472 S.E.2d at 255.)