Justia South Dakota Supreme Court Opinion Summaries

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The Supreme Court affirmed Defendant's conviction of first-degree murder and mandatory sentence of life in prison, holding that there as no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) Defendant's conviction was supported by sufficient evidence; (2) the decisions of the circuit court denying Defendant's request to strike expert DNA testimony and his motion to change venue were not outside the range of permissible discretionary choices; and (3) the court did not err in refusing sua sponte to strike the prosecutor's comment about the victim's father or to issue a curative instruction. View "State v. Krueger" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the decision of the circuit court granting summary judgment in favor of Defendants and dismissing Plaintiffs' request for a preliminary injunction alleging the existence of an easement allowing access to a gravel pit on Defendants' property, holding that the circuit court erred when it refused to recognize an easement implied by prior use.When Defendants attempted to block Plaintiffs' use of an access road to the gravel pit on Defendants' property Plaintiffs commenced the current action. The circuit court granted summary judgment for Defendants on Plaintiffs' easement implied by prior use claim. The Supreme Court reversed, holding that, under the circumstances of this case, the circuit court (1) erred in applying the substantive law and the standards required by S.D. Codified Law 15.6-56; and (2) erred when it granted Defendants' motion for summary judgment. View "Heumiller v. Hansen" on Justia Law

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The Supreme Court affirmed the order of the circuit court granting Defendants' motion for judgment on the pleadings and dismissing Plaintiff's fraud and deceit claims, holding that the claims were time barred.Plaintiff sued a law firm and its attorneys, alleging legal malpractice, fraud and deceit related to their representation of Plaintiff on criminal charges. The circuit court granted judgment on the pleadings for Defendants, concluding that the claims were time-barred by the three-year statute of repose for legal malpractice under S.D. Codified Laws 15-2-14.2. Plaintiff appealed, arguing that the circuit court erred in dismissing the fraud and deceit claims because those claims were subject to a six-year statute of limitations. The Supreme Court affirmed, holding (1) Plaintiff's fraud and deceit claims were subsumed within his malpractice claim; and (2) therefore, all of Plaintiff's claims were precluded under the repose statute. View "Slota v. Imhoff" on Justia Law

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The Supreme Court affirmed Defendant's conviction for first-degree burglary and grand theft, holding that the circuit court did not err when it denied Defendant's motion to suppress and when in denied Defendant's motion for expert fingerprint testing.Defendant filed a motion to suppress gun evidence that was returned to the owner before trial, arguing that the State would be unable to establish a proper chain of custody. The circuit court denied the motion to suppress. The Supreme Court affirmed, holding (1) although the law enforcement officers and the prosecutor did not comply with statutory standards before releasing the evidence to its owner, the circuit court did not err in denying the motion to suppress because the guns did not possess apparent exculpatory value; and (2) even if the circuit court abused its discretion by denying Defendant's request for fingerprint testing, there was no prejudice. View "State v. Zephier" on Justia Law

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The Supreme Court reversed the decision of the circuit court reversing the decision of the Department of Labor determining that sergeants in the Yankton Police Department are ineligible for membership in a collective bargaining unit because they have authority to hire or effectively recommend hiring decisions, holding that the circuit court erred in disturbing the Department's findings and conclusions.The City of Yankton filed a request with the Department to define the membership of a collective bargaining unit. After a hearing, the Department found that police sergeants have authority to hire or effectively recommend hiring and are thus excluded from membership in the collective bargaining unit. The circuit court reversed, holding that sergeants should be included in bargaining unit membership. The Supreme Court affirmed, holding (1) the circuit court erred in determining that the Department's relevant findings of fact were inadequate and that its conclusions of law were incorrect; and (2) the circuit court erred in determining that sergeants have no authority to hire or effectively recommend hiring decisions. View "Fraternal Order Of Police v. City Of Yankton" on Justia Law

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The Supreme Court affirmed Defendant's conviction of third-degree rape, holding that the State did not violate Defendant's right to due process by failing to interview the victim and that the circuit court did not err in determining that knowledge is not an element of the offense.Defendant was found guilty of third-degree rape in violation of S.D. Codified Laws 22-22-1(3), which makes it a crime for any person to sexually penetrate a victim incapable of giving consent because of physical or mental incapacity. The Supreme Court affirmed, holding that the circuit court (1) did not err when it denied Defendant's motion to dismiss; (2) did not err when it determined that knowledge is not an element of section 22-22-1(3); (3) did not abuse its discretion in restricting certain testimony; and (4) did not abuse its discretion when it denied Defendant's motion for a continuance. View "State v. Jackson" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the circuit court's property division order in this divorce proceeding, holding that the court abused its discretion in excluding farmland Wife purchased with Husband from the marital estate.A relative of Husband sold the farmland at issue to the parties at a discounted purchase price. Because of the discount the circuit court determined that the transfer was a partial gift solely to Husband. Wife appealed, arguing that the circuit court abused its discretion by excluding $1,526,000 of the farm's appraised value from the marital estate. The Supreme Court agreed, holding that the circuit court applied a rule that would conclusively prevent the entire value of the farm from ever being considered marital property regardless of Wife's contributions, and that the rule is in irreconcilable tension with existing decisional law. View "Field v. Field" on Justia Law

Posted in: Family Law
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The Supreme Court affirmed the judgment of the circuit court affirming Defendant's magistrate court conviction for operating an onsite wastewater system without a permit, holding that the City's ordinance as applied to Defendant was not an ex post facto law.Defendant was convicted for failure to obtain a permit in violation of Rapid City Municipal Code (RCMC) 13.20.800. On appeal, Defendant argued that RCMC 13.20.800 violated the ex post facto clauses of the state and federal constitutions, was preempted by state administrative rules, and exceeded Rapid City's authority since Defendant lived outside of the city's limits. The circuit court affirmed the conviction. The Supreme Court affirmed, holding (1) the City's sewerage permit ordinance was not an ex post facto law because it punished Defendant for conduct occurring after the ordinance was enacted; (2) RCMC 13.20.800 does not conflict with state administrative regulations; and (3) there was no merit to Defendant's argument that the City lacked authority to enforce the ordinance beyond its municipal boundaries. View "City Of Rapid City v. Schaub" on Justia Law

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The Supreme Court affirmed Defendant's conviction of second-degree rape and sexual contact involving a second victim, holding that Defendant's allegations of error were unavailing.Specifically, the Supreme Court held (1) the circuit court did not abuse its discretion by allowing evidence of Defendant's two prior alleged sexual assaults; (2) the admission of other act evidence did not violate Defendant's constitutional rights under the Double Jeopardy and Due Process Clauses; (3) the circuit court did not abuse its discretion when it denied Defendant's motion for a mistrial; (4) there was sufficient evidence to support the conviction; (5) the circuit court erred in admitting forensic laboratory reports by affidavit without affording Defendant the opportunity to cross-examine the analysts who conducted the testing and authored the reports, but the error was not prejudicial; and (6) Defendant's sentence did not violate the Eighth Amendment. View "State v. Taylor" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of aggravated assault and three counts of simple assault and ordering him to pay restitution to Medicaid for its coverage of the victim's medical expenses, holding that the circuit court did not err.Specifically, the Supreme Court held that the circuit court (1) did not commit plain error in finding that Medicaid qualified as a victim for purposes of restitution under S.D. Codified Laws 23A-28-2(5); (2) did not commit plain error by permitting testimony from two detectives that Defendant did not act in self-defense; and (3) did not abuse its discretion in denying Defendant's motion for a mistrial based on the prosecutor's statements during closing argument. View "State v. Bryant" on Justia Law

Posted in: Criminal Law