Justia South Dakota Supreme Court Opinion Summaries

Jeremy and Abbey Coyle brought a civil trespass action against Kenneth and Kelli McFarland, alleging that a portion of the McFarlands’ driveway and vehicles encroached on the Coyles’ property, Lot Q1, in Belle Fourche, South Dakota. The dispute centered on whether a public right-of-way (Walworth Street) extended along the entire southeastern boundary of the McFarlands’ Lot 25A, which would affect the property boundaries and the alleged trespass. The Coyles claimed the right-of-way ended at a certain point, while the McFarlands argued it continued along the full boundary, relying on subdivision plats, improvement agreements, and city ordinances.After the Coyles filed their complaint, the McFarlands answered and asserted their defense based on the Subdivision Improvements Agreement and city records. The Coyles then moved for partial summary judgment before any discovery had occurred. The McFarlands failed to respond within the statutory deadline and subsequently moved for a continuance under SDCL 15-6-56(f), submitting affidavits explaining the need for additional discovery and citing personal circumstances for the delay. The Circuit Court for the Fourth Judicial Circuit, Butte County, denied the continuance and granted partial summary judgment to the Coyles, finding the right-of-way ended as the Coyles claimed and ordering the McFarlands to remove their assets from Lot Q1. The court later denied the McFarlands’ motion for reconsideration and motion for relief from judgment.On appeal, the Supreme Court of South Dakota held that the circuit court abused its discretion by denying the McFarlands’ motion for a continuance. The Supreme Court found that the McFarlands’ affidavits met the requirements for additional time under Rule 56(f), that excusable neglect was present due to counsel’s personal circumstances, and that no prejudice to the Coyles was shown. The Supreme Court reversed the circuit court’s orders and remanded for further proceedings. View "Coyle v. Mcfarland" on Justia Law

RTI, LLC and RTI Holdings, LLC sought to construct a specialized clinical research facility in Brookings, South Dakota, designed for animal health research trials with stringent air filtration and ventilation requirements. Acting as the general contractor, RTI hired designArc Group, Inc. as architect and several contractors, including Pro Engineering, Inc., Ekern Home Equipment Company, FM Acoustical Tile, Inc., and Trane U.S. Inc., to design and build the facility. After completion in April 2016, RTI experienced significant issues with air pressure, ventilation, and ceiling integrity, leading to contamination problems that disrupted research and resulted in financial losses.The Circuit Court of the Third Judicial Circuit, Brookings County, reviewed RTI’s claims for breach of contract and breach of implied warranties against the architect and contractors. All defendants moved for summary judgment, arguing that RTI’s claims were based on professional negligence and required expert testimony, which RTI failed to provide. The circuit court agreed, finding RTI’s CEO unqualified as an expert, and granted summary judgment to all defendants. The court also denied RTI’s motion to amend its complaint to add negligence claims, deeming the amendment untimely and futile due to the lack of expert testimony.The Supreme Court of the State of South Dakota affirmed the summary judgment for designArc, Pro Engineering, and FM Acoustical, holding that expert testimony was required for claims involving specialized design and construction issues, and that RTI’s CEO was not qualified to provide such testimony. However, the court reversed the summary judgment for Trane and Ekern, finding genuine issues of material fact regarding Trane’s alleged faulty installation and Ekern’s potential vicarious liability. The court also reversed the denial of RTI’s motion to amend the complaint, concluding the proposed amendments were not futile and would not prejudice Trane or Ekern. The case was remanded for further proceedings. View "RTI, LLC v. Pro Engineering" on Justia Law

A married couple owned a waterfront property in Canada, which was destroyed by fire during their divorce proceedings. The wife, who was living at the Canadian property, disclosed during discovery that there was a single insurance policy with a $2 million Canadian Dollar (CAD) limit covering the property. The parties entered into a stipulation and agreement, incorporated into the divorce decree, which awarded the wife the Canadian property and the related insurance proceeds. Several months later, the husband learned that the wife was actually receiving $4 million CAD in insurance proceeds, not the $2 million CAD previously disclosed. He alleged that the wife had concealed an additional insurance policy and sought relief from the divorce judgment on grounds of fraud.The Circuit Court of the Second Judicial Circuit, Minnehaha County, South Dakota, reviewed the husband’s motion for relief under SDCL 15-6-60(b)(3). After a hearing based on affidavits and documentary evidence, the court found that the wife had committed fraud by intentionally concealing the additional insurance policy. The court ordered the wife to produce all insurance policies in effect at the time of the fire and directed that any insurance proceeds exceeding $2 million CAD be split equally between the parties, in accordance with their agreement and SDCL 25-4-77. The court also awarded attorney fees to the husband and issued a stay allowing the wife to use the insurance proceeds to rebuild the property, with any excess to be held in trust.On appeal, the Supreme Court of the State of South Dakota held that the circuit court’s finding of fraud was not clearly erroneous and affirmed the grant of Rule 60(b) relief. The Supreme Court remanded the case for further proceedings to determine the appropriate division of assets under the current circumstances, given the stay and use of insurance proceeds for reconstruction. The Supreme Court also awarded appellate attorney fees to the husband. View "Trumble v. Trumble" on Justia Law

A man was convicted of three counts of sexual contact with a developmentally disabled adult neighbor, D.W., who functioned at the intellectual level of a seven-year-old. The incidents occurred during a Fourth of July celebration at the defendant’s home, involving inappropriate touching on a four-wheeler, on a hot tub, and behind a trailer. D.W. reported the incidents to his mother, who was his court-appointed guardian. The mother recorded a phone call in which the defendant made incriminating statements about the incidents. D.W. was later evaluated by a physician specializing in abuse of developmentally disabled individuals.The Circuit Court of the Second Judicial Circuit, Minnehaha County, presided over the trial. The court allowed D.W. to testify while holding a stuffed animal for comfort, over the defendant’s objection. The court denied the defendant’s motions for judgment of acquittal at the close of the State’s evidence and at the end of trial. The jury found the defendant guilty on all three counts. The defendant appealed, challenging the allowance of the stuffed animal, the sufficiency of the evidence, and two other issues not preserved for appeal: the physician’s testimony and the State’s cross-examination.The Supreme Court of the State of South Dakota reviewed the case. It held that the circuit court did not abuse its discretion in allowing D.W. to testify with a stuffed animal, as courts have broad authority to manage witness testimony and accommodations. The Supreme Court also found no plain error in the State’s cross-examination or the physician’s testimony, and concluded that sufficient evidence supported the convictions. The Supreme Court affirmed the convictions and all rulings of the circuit court. View "State v. Richter" on Justia Law

Roger Cunningham opened an IRA during his marriage to Sheila, naming her as the sole beneficiary. The couple, long-time Tennessee residents, later divorced in 2015. Their Marital Dissolution Agreement, incorporated into a Tennessee court’s final divorce decree, awarded Sheila a specific sum from the IRA and required her to relinquish any further claim to the account. Roger moved to South Dakota before the divorce was finalized but did not update the IRA’s beneficiary designation. After Roger’s death in South Dakota, his daughter Susan, as personal representative of his estate, discovered that the IRA had been transferred to Sheila, still listed as the beneficiary.Following Roger’s death, Susan initiated informal probate proceedings in South Dakota and sought a declaration from the Second Judicial Circuit Court that, under South Dakota’s revocation-on-divorce statute (SDCL 29A-2-804), Sheila’s beneficiary status had been automatically revoked by the divorce, making the IRA part of the estate. Sheila, a Tennessee resident, appeared specially to contest jurisdiction and the procedural propriety of the Estate’s motion, arguing that the court lacked personal jurisdiction over her and that the matter should have been brought as a separate action. The circuit court ruled in favor of the Estate, finding it had jurisdiction and that the statute revoked Sheila’s beneficiary designation, thus including the IRA in the estate.On appeal, the Supreme Court of the State of South Dakota held that the circuit court lacked personal jurisdiction over Sheila. The Supreme Court found that Sheila’s only connection to South Dakota was her receipt of the IRA funds, which resulted from Roger’s unilateral actions, not from any purposeful availment by Sheila of South Dakota’s laws. The Supreme Court vacated the circuit court’s order and remanded with instructions to grant Sheila’s motion to dismiss, declining to address the procedural issue. View "Estate Of Cunningham" on Justia Law

In April 2018, Mark Fiechtner was involved in a motor vehicle accident in Lincoln County, South Dakota, caused by another driver, Caitlyn Belliveau, who lost control on icy roads. Fiechtner subsequently experienced neck pain, headaches, vision problems, and memory issues, seeking treatment from various healthcare providers. He held an insurance policy with American West Insurance Company, which paid the $10,000 medical benefits limit. Fiechtner also received the $100,000 liability limit from Belliveau’s insurer. He then sought $900,000 in underinsured motorist (UIM) benefits from American West, but was offered only $10,000. After unsuccessful negotiations, Fiechtner sued American West for breach of contract, bad faith, punitive damages, and attorney fees.The case was tried in the Circuit Court of the Second Judicial Circuit, Lincoln County, South Dakota. At trial, evidence showed that American West’s investigation of the UIM claim was limited and did not include contacting Fiechtner or his healthcare providers, nor reviewing prior claim notes. The jury found in favor of Fiechtner on all counts, awarding $400,000 for breach of contract, $250,000 for bad faith, $890,000 in punitive damages, and attorney fees. The circuit court denied American West’s post-trial motions for judgment as a matter of law and for a new trial.The Supreme Court of the State of South Dakota reviewed the case. It affirmed the circuit court’s denial of American West’s motions, holding that sufficient evidence supported the jury’s findings of bad faith and punitive damages, and that the circuit court did not clearly err in awarding attorney fees under SDCL 58-12-3. The Supreme Court also found no abuse of discretion in the circuit court’s evidentiary rulings. View "Fiechtner v. American West Ins." on Justia Law

Soloman Longchase was charged with multiple offenses, including aggravated assault (domestic), aggravated kidnapping, grand theft, interference with emergency communication, and false impersonation to deceive law enforcement, stemming from incidents on August 20, 2022. After the initial complaint and indictment, Longchase was held in the Hughes County Jail on unrelated charges. He was granted a medical furlough but failed to return, resulting in an escape charge and a period as a fugitive until his rearrest in December 2023. He later appeared in court for the Hyde County charges, was appointed counsel, and ultimately entered a plea agreement to plead guilty to grand theft and simple assault, with other charges dismissed.The Circuit Court of the Sixth Judicial Circuit, Hyde County, presided over the case. Longchase moved to dismiss the indictment, alleging a violation of his constitutional right to a speedy trial. The circuit court denied the motion after applying the Barker v. Wingo factors. At sentencing, the court ordered Longchase to reimburse the county for court-appointed attorney fees, finding he had the ability to work and pay after release from prison. Longchase objected, arguing the court was required to make specific findings about his ability to pay and that recoupment was unconstitutional given his current financial status.The Supreme Court of the State of South Dakota reviewed the case. It held that Longchase’s unconditional guilty plea waived his right to appeal the alleged speedy trial violation, as the right to a speedy trial is not a jurisdictional defect that survives a guilty plea. The court also held that the circuit court’s order requiring reimbursement of attorney fees did not violate Longchase’s constitutional rights to counsel or due process, as he was afforded counsel at all critical stages and had a meaningful opportunity to contest the recoupment order. The Supreme Court affirmed the circuit court’s rulings. View "State v. Longchase" on Justia Law

A couple divorced in 2019, with the husband required to pay monthly alimony to the wife under the terms of their agreement. After the sale of the marital home, the husband’s alimony obligation was set at $13,500 per month. In 2023, the husband relocated to Texas, left his previous employment, and experienced a significant decrease in income. He struggled to meet his alimony obligations, missing several payments, and ultimately sought a reduction in his alimony due to his changed financial circumstances. The wife, whose dental hygiene license had lapsed and who was not employed, relied primarily on alimony for her income and filed a motion for contempt based on the missed payments.The Circuit Court of the Second Judicial Circuit, Lincoln County, South Dakota, reviewed the parties’ motions. After considering testimony and financial documentation, the court found the husband’s account of his reduced income credible and determined that his move and employment changes were not made in bad faith or to avoid alimony. The court also found that the wife’s claimed financial needs were not fully credible, noting that some expenses were inflated or related to adult children. The court reduced the husband’s alimony obligation to $6,000 per month effective January 1, 2025, denied the wife’s contempt motion, and declined to make the modification retroactive, reasoning that the wife should have time to adjust to the reduced payments.On appeal, the Supreme Court of the State of South Dakota affirmed the circuit court’s decisions. The Supreme Court held that the circuit court did not abuse its discretion in modifying the alimony obligation, did not clearly err in denying the contempt motion, and did not abuse its discretion in refusing to apply the modification retroactively. The court’s findings were supported by the evidence and were within the permissible range of judicial decisions. View "Peery v. Peery" on Justia Law

The case concerns the conviction of Dion Bordeaux for first-degree murder following the shooting death of his girlfriend, Jeanette Jumping Eagle, in a Rapid City hotel room on January 1, 2020. Only Bordeaux and his brother Giovanni were present at the time of the shooting. Giovanni testified that Bordeaux and Jeanette had been arguing, and after hearing a gunshot while in the bathroom, he saw Bordeaux panicking. Bordeaux called 911, claiming Jeanette shot herself. Law enforcement found Jeanette deceased with a gunshot wound, her hand on a handgun, and evidence of blood transfer and gunshot residue. Bordeaux was arrested on an unrelated aggravated assault charge from September 2019, which later became central to the case.The Seventh Judicial Circuit Court, Pennington County, presided over the trial. The State sought to admit evidence of Bordeaux’s prior aggravated assault against his cousin, arguing it showed intent and a common scheme. The circuit court allowed this evidence, finding similarities between the two incidents. At trial, the State presented extensive forensic evidence and testimony, including details of the prior assault. Bordeaux’s defense argued that Jeanette’s death was a suicide, not homicide, and objected to the admission of the prior assault evidence, claiming it was prejudicial and not sufficiently similar to the charged offense.The Supreme Court of South Dakota reviewed the case. It held that the circuit court abused its discretion by admitting the prior aggravated assault evidence, finding insufficient similarity between the two incidents to justify its use for proving intent or a common scheme. The Court further determined that the admission of this evidence was prejudicial, as it was a significant part of the State’s case and likely influenced the jury’s verdict. The Supreme Court reversed Bordeaux’s conviction and remanded the case for a new trial. View "State v. Bordeaux" on Justia Law

Dakota Bay, LLC owns property adjacent to McCook Lake in Union County, South Dakota, and planned to construct a canal connecting its land to the lake. To facilitate this, Dakota Bay’s owner, Michael Chicoine, applied for a shoreline alteration permit and a water permit to use an existing irrigation well to fill and maintain the canal. The McCook Lake Recreation Area Association, which holds a permit to pump water from the Missouri River into McCook Lake, opposed the project. The Association argued that constructing the canal would require a permit to appropriate water from McCook Lake and that the canal would increase water loss from the lake, potentially impairing the Association’s ability to maintain lake levels.The South Dakota Department of Agriculture and Natural Resources Water Management Board held hearings and ultimately denied the Association’s petition for a declaratory ruling, finding that the canal’s construction would not constitute an appropriation of water from McCook Lake. The Board also granted Dakota Bay’s application to use well water for the canal, finding that unappropriated water was available, the use was beneficial and in the public interest, and that it would not unlawfully impair existing water rights. The Association appealed both decisions to the Circuit Court of the First Judicial Circuit, which affirmed the Board’s rulings and also upheld the Board’s decision to quash subpoenas issued by the Association.On further appeal, the Supreme Court of the State of South Dakota affirmed the circuit court’s decisions. The Court held that constructing the canal would not result in an appropriation of water from McCook Lake and thus did not require a water appropriation permit. The Court also held that Dakota Bay’s proposed use of well water for the canal was a beneficial use in the public interest and that the Board did not abuse its discretion in quashing the subpoenas, clarifying that administrative proceedings are governed by the Administrative Procedures Act, not the rules of civil procedure. View "Mccook Lake Recreation Area V. Dakota Bay, LLC" on Justia Law