A Conway caregiver’s arrest centers on a property transaction completed under existing deed rules while lawmakers consider a new title-theft felony.
CONWAY, S.C. — A deed transferring a 75-year-old man’s home to his caregiver for a stated $5 has become evidence in a criminal case and a separate civil dispute, highlighting the difference between recording a legally formatted property document and determining whether the transaction behind it was lawfully obtained.
Conway police arrested Sarah Smalls, 58, on Sept. 28 and charged her with exploitation of a vulnerable adult, breach of trust with fraudulent intent and perjury. The case involves Robert Rowland, who owned a home in Conway and died in June 2024. Arrest warrants reported by WMBF accuse Smalls of unlawfully gaining control of his finances and obtaining his property while he was vulnerable. Smalls posted bond and has not been convicted. The disputed deed remains subject to a civil challenge by Rowland’s daughter.
The property document is unusual because of both its timing and its stated consideration. Authorities say Smalls obtained the deed to Rowland’s Ackerrose Drive home on April 17, 2024, not long after she began caring for him. The document listed $5 as consideration for the transfer. A low stated amount does not automatically make a deed unlawful, but police allege the transaction was part of a broader effort to exploit Rowland. His daughter, Nora Rowland, has said her father had Parkinson’s disease and a brain injury and did not understand what he was signing.
South Carolina’s recording system is not designed to adjudicate every dispute surrounding a deed at the moment the document is filed. State law requires formal elements that include the owner’s signature, two witnesses and a notarized acknowledgment. When a document appears to meet recording requirements, a county office can accept it without conducting the type of investigation a judge or police detective might later undertake into capacity, coercion, fraud or undue influence. That distinction became part of the public discussion when Nora Rowland began contesting the transfer of her father’s home.
Police now allege additional circumstances that go beyond the face of the deed. Warrants say Smalls had a family member notarize the document. A probate complaint filed by Nora Rowland identifies the notary as Smalls’ sister. The warrants also state that Smalls was denied the deed by one law office before obtaining it through another. Those allegations may be used by prosecutors as they seek to establish how the transfer occurred and whether Smalls acted with fraudulent intent. A court has not yet determined the criminal significance of those facts.
The case arrives while South Carolina lawmakers are separately considering legislation aimed specifically at deed and title theft. Senate Bill 822 was introduced in January 2026, months before Smalls’ arrest. The measure would add a new section to state law defining title theft and creating a felony offense. The Senate approved the bill in April and sent it to the House, where it was referred to the Judiciary Committee in May. Legislative records reviewed Nov. 10 show no later action moving the measure out of that committee.
The Senate-approved language defines title theft as unlawfully transferring or attempting to transfer an owner’s title or deed without the owner’s effective consent or with intent to deprive the owner of an interest in the real estate. The proposal is broader than the facts of any one case and was not written specifically for the Rowland dispute. Its relevance is that it addresses the same general problem now alleged in Conway: whether someone wrongfully obtained ownership rights through a recorded real-estate instrument.
Smalls is being prosecuted under laws already available to authorities rather than the pending deed-theft measure. The exploitation charge focuses on Rowland’s alleged vulnerability, while the breach-of-trust accusation concerns property and financial control police say Smalls wrongfully exercised. The perjury charge stems from a different set of documents. According to the warrants, Smalls allegedly supplied false information in May 2024 while seeking assistance from the Housing Authority of Conway, including claims regarding assets, real estate, cash and future employment.
The criminal accusations also extend far beyond the house. Warrants allege that Smalls acquired power of attorney over Rowland and took over management of his financial affairs between March and July 2024. Police say she withdrew more than $17,000 in cash and transferred money to her own Cash App multiple times. WMBF reported separately that it reviewed bank records showing payments between Rowland and Smalls. Whether those transactions were authorized, improperly induced or criminal will be a central factual issue as the case moves through court.
Nora Rowland’s account provides the background to how the transactions came under scrutiny. She said Smalls entered her father’s life through Griswold Care Pairing for Myrtle Beach in March 2024. Rowland lived in Maryland and said she normally communicated with her father frequently. She became worried when she heard from him less often. On a trip to Conway around Father’s Day that June, she said she reached his home without knowing he had died three days earlier and was informed of his death through the residence’s Ring doorbell system.
The trip also brought the property dispute into the open. Nora Rowland said she discovered that Smalls held a deed to the home and later found the interior altered from the way she remembered it. During the confrontation, Smalls accused Rowland and her partner of being in the property unlawfully. Conway police arrested Rowland on a second-degree burglary accusation. Prosecutors later dismissed that charge. Two years afterward, Conway police arrested Smalls in connection with the financial and property dealings involving Robert Rowland.
The competing legal proceedings illustrate why a recorded deed does not always mark the end of an ownership dispute. Recording creates a public record of a claimed transfer, but courts can still be asked to determine whether a deed was validly obtained and what legal effect it should have. Nora Rowland continues to challenge the transfer in civil court. That proceeding can address ownership and related property questions even while prosecutors separately pursue criminal accusations concerning Smalls’ conduct.
Griswold has said Smalls was an independent caregiver listed in its system and passed a required background check before she was referred to Rowland. The company said its records show Rowland received services for only a brief period and was no longer receiving care through Griswold when the power of attorney and property transfer occurred. It also said Smalls had no substantiated findings of abuse, neglect or property misappropriation listed on the state nurse aide registry at the time of its review.
The company has said it made reports to appropriate state organizations after learning more about the allegations and is cooperating with authorities. That position does not address the ultimate validity of the deed or the criminal accusations. Those questions belong to the courts. Smalls did not respond to WMBF reporters as she left detention following her bond hearing, and earlier directed questions about the case to an attorney without providing the attorney’s information, the station reported.
Smalls received a $20,000 bond on the exploitation charge, $20,000 on the breach-of-trust charge and $5,000 on the perjury count. She posted bond Sept. 29. Her first court appearance was reported as scheduled for Dec. 11, while the civil deed challenge remains pending. At the state Capitol, Senate Bill 822 also remains unresolved in the House Judiciary Committee. Neither the criminal prosecution, the property litigation nor the proposed change to South Carolina deed-theft law had reached a final resolution as of Nov. 10.
Author note: Last updated Nov. 10, 2026.