Justia South Dakota Supreme Court Opinion Summaries

Michael David Geist was convicted of simple assault on a law enforcement officer and criminal trespass following a jury trial. The incident occurred on April 14, 2023, when Officer Dalton Santana responded to a report of a disruptive male patron at the Mount Rushmore Casino. Geist, identified as the disruptive individual, was irascible and under the influence of a substance. When Officer Santana attempted to transport Geist to a detoxification center, Geist resisted, resulting in a physical altercation where Geist allegedly kicked Officer Santana.The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, admitted a recording from Officer Zachary Simons’s body camera under the silent witness theory, despite Geist’s objection. Geist argued that the recording should not be admitted without Officer Simons’s testimony, as he was unavailable due to military deployment. The court overruled the objection, admitting the footage based on the testimony of James Chastain, a video evidence technician, who authenticated the recording.The Supreme Court of the State of South Dakota reviewed the case. The court held that the circuit court did not abuse its discretion in admitting the body camera footage under the silent witness theory. The court found that sufficient foundational facts were presented to authenticate the video, including the technical details of the body camera system and the consistency of the footage with other unchallenged evidence. The court also determined that even if the admission was erroneous, it did not prejudice Geist, as the other evidence presented was strong and consistent with the State’s case. Consequently, the Supreme Court affirmed the circuit court’s decision. View "State v. Geist" on Justia Law

Bighorn Construction, LLC (Bighorn) and JED Spectrum, Inc. (JED) filed mechanic’s liens against property owned by Keith Stoakes, seeking to foreclose on the liens. Stoakes denied the validity of the liens and counterclaimed for slander of title against both companies, and for breach of contract, promissory estoppel, and fraud against JED. After a bench trial, the circuit court denied Bighorn’s and JED’s claims for lien foreclosure and ruled in favor of Stoakes on his slander of title claims, awarding him $252,225.27 in damages and $33,394.20 in attorney fees. The court denied relief on the remaining claims.The circuit court found that Bighorn had no reasonable grounds to file the lien after receiving a check for full payment, and that JED’s lien was untimely and insufficiently itemized. The court also found that Stoakes reasonably relied on JED’s promise of a shared well system, awarding him damages for promissory estoppel. However, the court later reversed its decision on the promissory estoppel claim and reduced the attorney fee award accordingly.The Supreme Court of South Dakota reviewed the case. It reversed the circuit court’s ruling on the slander of title claims, finding insufficient evidence to prove that Jerry, acting on behalf of Bighorn and JED, knew or recklessly disregarded the falsity of the liens. The court affirmed the denial of Stoakes’s promissory estoppel claim, concluding that Stoakes did not suffer substantial economic detriment. The court also affirmed the attorney fee award of $33,394.20 to Stoakes, as it was within the court’s discretion under SDCL 44-9-42. View "Jed Spectrum, Inc. v. Stoakes" on Justia Law

Richard Hillyer, an inmate at the Pennington County Jail, was convicted of possessing a weapon, specifically an altered razor blade, in violation of SDCL 24-11-47(3). Hillyer had checked out a jail-issued razor, removed the blade, broke it in half, and concealed one half in his mouth while flushing the other half. He claimed he kept the blade to cut himself to relieve anxiety, not to harm others. Jail staff discovered the blade after Hillyer admitted to possessing it and handed it over to Sergeant James Hogue.The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, presided over Hillyer's trial. The jury found him guilty of the felony charge. Hillyer appealed, arguing that the court erred by rejecting his lesser-included offense instruction, denying his motion for judgment of acquittal due to insufficient evidence, and refusing to instruct the jury not to consider hypothetical uses of the razor blade. He also claimed that the cumulative effect of these errors deprived him of a fair trial.The Supreme Court of the State of South Dakota reviewed the case. The court held that the lesser-included offense instruction was correctly denied because the elements of the lesser offense were not a subset of the greater offense. The court found sufficient evidence to support the jury's verdict, noting that the razor blade could be considered a weapon as defined by law. The court also ruled that the trial court did not abuse its discretion in referring the jury to the existing instructions when they asked about hypothetical uses of the razor blade. The court affirmed the conviction, concluding that Hillyer received a fair trial. View "State v. Hillyer" on Justia Law

Isaiah Rouse was convicted of three counts of aggravated assault against law enforcement officers and one count of threatening a law enforcement officer. The incidents occurred while Rouse was in custody at Hughes County Jail. On January 13, 2023, Rouse threatened to stab a correctional officer if he did not receive his medication. When officers attempted to control the situation, Rouse refused to comply, made further threats, and held a sharpened pencil in a menacing manner. On February 25, 2023, Rouse threatened another officer, stating he would stab him upon release from jail.The Circuit Court of the Sixth Judicial Circuit denied Rouse's motion to dismiss the indictment for violating the 180-day rule, excluded certain days from the calculation, and denied his motion for judgment of acquittal. The court allowed the State to introduce evidence that Rouse was in jail for a prior aggravated assault involving a stabbing, which the court deemed relevant to show the officers' fear and Rouse's intent. The jury found Rouse guilty on all counts.The Supreme Court of South Dakota reviewed the case. The court affirmed the lower court's decision in part, reversed in part, and remanded for a new trial on the aggravated assault counts. The court held that the evidence of Rouse's prior aggravated assault was improperly admitted as it was not res gestae and did not meet the criteria for other acts evidence under SDCL 19-19-404(b). The court found that this error was prejudicial, as it could have influenced the jury's decision. The court also addressed the jury instructions, finding no abuse of discretion in the instructions given. The case was remanded for a new trial on the aggravated assault charges, while the conviction for threatening a law enforcement officer was upheld. View "State v. Rouse" on Justia Law

Tom Smith Masonry (Smith Masonry) and WIPI Group USA, Inc. (WIPI) entered into a contract for Smith Masonry to construct a fence on WIPI’s property. After completing most of the work, Smith Masonry requested final payment, which WIPI withheld due to a dispute over the installation of a gate operator. Smith Masonry filed a mechanic’s lien and subsequently a lawsuit to foreclose on the lien, seeking the unpaid balance. WIPI counterclaimed for breach of contract and other issues, seeking damages for alleged faulty workmanship.The Circuit Court of the Second Judicial Circuit, Lincoln County, South Dakota, denied relief to both parties, finding that Smith Masonry’s work was defective and that WIPI’s damages were not established with exactitude. Smith Masonry appealed, and the South Dakota Supreme Court reversed and remanded, directing the lower court to enter a judgment of foreclosure in favor of Smith Masonry for the full amount of the lien and to reconsider Smith Masonry’s request for attorney fees.On remand, the circuit court entered a judgment in favor of Smith Masonry on the lien but denied the request for attorney fees. Smith Masonry appealed again. The South Dakota Supreme Court found that the circuit court violated the law of the case doctrine by revisiting issues already settled in the first appeal and by speculating on what might have occurred had the trial resumed. The Supreme Court also held that the circuit court abused its discretion by denying attorney fees based on irrelevant factors and an overly narrow interpretation of the statute governing attorney fees in mechanic’s lien cases.The South Dakota Supreme Court reversed the circuit court’s denial of attorney fees and remanded for a determination of an appropriate award of attorney fees consistent with its opinion. The court also awarded Smith Masonry $30,000 for appellate attorney fees. View "Smith Masonry v. Wipi Group Inc." on Justia Law

Sammy Shepley, acting pro se, pled no contest to failing to provide notice of a new address as a registered sex offender and admitted to being a habitual offender. He was sentenced to a suspended five-year penitentiary term with two years of probation. Shepley appealed, arguing that the circuit court failed to adequately advise him of the risks of self-representation and abused its discretion by denying his request for substitute counsel.The Circuit Court of the Sixth Judicial Circuit in Hughes County initially appointed attorney Katie Thompson to represent Shepley, but she withdrew due to a breakdown in the attorney-client relationship. Attorney Cody Honeywell was then appointed but also withdrew after Shepley expressed a desire to represent himself. The court allowed Shepley to proceed pro se with Honeywell as standby counsel. Shepley later negotiated a plea agreement directly with the State, resulting in a no contest plea and an admission to the habitual offender charge.The Supreme Court of the State of South Dakota reviewed the case. The court found that the circuit court had adequately informed Shepley of the risks of self-representation, noting that Shepley had extensive experience with the criminal justice system and had been informed of the nature of the charges, his right to counsel, and the potential penalties. The court also determined that Shepley’s request to represent himself was unequivocal and that he had not made a formal request for substitute counsel after Honeywell’s withdrawal.The Supreme Court held that Shepley’s waiver of his right to counsel was knowing, voluntary, and intelligent. The court affirmed the circuit court’s decision, concluding that there was no abuse of discretion in allowing Shepley to represent himself and in not appointing substitute counsel. View "State v. Shepley" on Justia Law

Nathan Parris was taken into protective custody by law enforcement after making suicidal statements and exhibiting concerning behavior. Officers searched him before transporting him to the hospital for a mental health evaluation and found a small, closed container in his pocket, which contained methamphetamine. Parris was charged with possession of a controlled substance and moved to suppress the drug evidence, arguing that the search of the container was impermissible.The Circuit Court of the Seventh Judicial Circuit in Pennington County, South Dakota, denied Parris's motion to suppress, finding that the officers had probable cause to take him into protective custody and that the search of the container was permissible. Parris was found guilty of possession of a controlled substance in a court trial based on stipulated facts.The Supreme Court of the State of South Dakota reviewed the case. The court held that the officers had probable cause to believe that Parris required emergency intervention due to his suicidal statements, emotional distress, and possession of a loaded handgun. The court also held that the search of the closed container was a reasonable administrative step to ensure the safety of Parris, the officers, and the facility, and was not conducted as part of a criminal investigation. Therefore, the search did not violate the Fourth Amendment.The Supreme Court affirmed the circuit court's decision, upholding Parris's conviction for possession of a controlled substance. View "State v. Parris" on Justia Law

The plaintiffs are seven members of the South Dakota Air National Guard who also work as federal civilian employees of the Department of the Air Force. They are entitled to 15 days of paid military leave each year in their civilian roles. They allege that the Adjutant General wrongfully denied them military leave while they were serving on active duty, in violation of the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA).The Circuit Court of the Second Judicial Circuit, Minnehaha County, South Dakota, dismissed the USERRA claims sua sponte without reaching the merits of the parties’ arguments. The court concluded that the plaintiffs must demonstrate the existence of an antimilitary animus to prevail under USERRA. The plaintiffs appealed this decision.The Supreme Court of the State of South Dakota reviewed the case and concluded that the plaintiffs are entitled to military leave. The court held that the plaintiffs do not need to show antimilitary animus because the benefit in question, military leave, is only available to members of the military. The court found that the plaintiffs' Title 10 orders converted their status from state militia members to federal service members, making them eligible for the 15 days of paid military leave under 5 U.S.C. § 6323(a)(1). The court reversed the circuit court’s decision and remanded the case for further proceedings consistent with its opinion. View "Christiansen v. Morrell" on Justia Law

The City of Tea passed a resolution imposing a special assessment on properties abutting a road construction project, including property owned by KJD, LLC. The City found that the improvement conferred special benefits on the abutting properties beyond those experienced by the public. KJD objected to the assessment, arguing it was unconstitutional as the project did not confer a special benefit on its property. The circuit court held that KJD did not rebut the presumption that the City’s assessment was valid and did not prove by clear and convincing evidence that the City’s findings were incorrect, thus denying KJD’s objection.KJD appealed to the Supreme Court of South Dakota. The Supreme Court reviewed the case de novo, noting that the City’s findings in its resolution are presumed correct and that KJD had the burden to rebut this presumption with substantial, credible evidence. The Court found that KJD failed to present such evidence. The City’s findings included that the project would improve aesthetics, safety, and access to the properties, which are considered special benefits. The Court also noted that the City’s method of calculating the assessment based on the cost of the project was constitutionally permissible.The Supreme Court of South Dakota affirmed the circuit court’s decision, holding that KJD did not meet its burden of proving by clear and convincing evidence that the City’s special assessment was unconstitutional. The Court concluded that the City’s findings were supported by the record and that the special assessment did not exceed the value of the benefits conferred on KJD’s property. View "KJD, LLC v. City Of Tea" on Justia Law

In September 2015, Josh Brewer suffered a work-related injury while employed by Tectum Holdings, Inc. d/b/a Truxedo. Brewer filed a workers' compensation claim for permanent total disability (PTD) benefits, which was denied by his employer and their insurer, Berkshire Hathaway. Brewer's claim was initially denied by an administrative law judge (ALJ) and subsequently by the Department of Labor (Department), which found that Brewer did not prove his work-related injury was a major contributing cause of his current condition and ongoing need for treatment. Brewer appealed the Department's decision to the circuit court, which affirmed the Department's ruling. Brewer then appealed to the Supreme Court of South Dakota.The Supreme Court of South Dakota reviewed the case de novo, focusing on the documentary evidence and expert testimonies. The court found that Brewer's treating physician, Dr. Rothrock, provided a more credible causation opinion than the employer's expert, Dr. Jensen. Dr. Rothrock opined that Brewer's work injury was a major contributing cause of his current condition and need for treatment, based on his personal treatment of Brewer and the results of various diagnostic tests. The court concluded that Brewer met his burden of proving causation and reversed the Department's determination on this issue.Regarding Brewer's claim for PTD benefits, the court reviewed the ALJ's findings for clear error. The court found that Brewer did not establish obvious unemployability due to his physical condition, age, training, and experience. Additionally, Brewer's job search efforts were deemed unreasonable, as he did not follow application instructions and highlighted his physical limitations on his résumé. The court also noted that the employer presented sufficient evidence of suitable employment opportunities available to Brewer within his limitations. Consequently, the court affirmed the Department's denial of PTD benefits.The Supreme Court of South Dakota affirmed in part and reversed in part, remanding the case for further proceedings consistent with its opinion. View "Brewer v. Tectum Holdings" on Justia Law