Justia South Dakota Supreme Court Opinion Summaries

Kevin Rowe filed a lawsuit against his ex-wife, Dione Rowe, alleging tortious interference with a business relationship. Dione, with the help of her daughters, sent a letter to the Tribal Land Enterprise (TLE) making disparaging allegations against Kevin, who leased Tribal-owned land from the TLE. The letter requested the TLE to cancel Kevin’s leases and lease the land to her daughters instead. The TLE rescinded Kevin’s leases at their next board meeting, leading Kevin to file the lawsuit.The Circuit Court of the Sixth Judicial Circuit in Tripp County, South Dakota, denied Dione’s motion for summary judgment, which argued that her letter was an absolutely privileged communication under SDCL 20-11-5(2). The court concluded that the TLE meeting was a quasi-judicial proceeding but held that the privilege did not apply because the TLE did not follow its own procedures, including providing notice to Kevin.The Supreme Court of the State of South Dakota reviewed the case and reversed the circuit court’s decision. The Supreme Court held that the absolute privilege under SDCL 20-11-5(2) applies to claims of tortious interference with a business relationship. The court found that the TLE board meeting was an official proceeding authorized by law and that Dione’s letter had a logical relation to the TLE’s proceedings. The court also determined that the lack of notice to Kevin did not negate the privilege. Additionally, the court concluded that Dione did not waive the privilege by failing to plead it in her answer, as the issue was tried by implied consent during the summary judgment proceedings. The Supreme Court directed the lower court to enter summary judgment in favor of Dione. View "Rowe v. Rowe" on Justia Law

The Nelson Estate claimed an interest in a coin shop and alleged conversion of its property. Dr. Earl Nelson had provided funds for the business, resulting in a 50% ownership interest, which was confirmed by William Tinkcom. After Dr. Nelson's death in 2013, Tinkcom continued to operate the business and assured Nelson's heirs of their 50% interest. Tinkcom died in 2022, and the business was sold to Eddie Welch without including the Nelson Estate in the final agreement. The Nelson Estate sued the Tinkcom Estate, Welch, and Mere Coin Company, LLC, for breach of contract, unjust enrichment, and other claims, including conversion of valuable coins and collectibles.The Circuit Court of the Second Judicial Circuit in Minnehaha County, South Dakota, granted the defendants' motion for judgment on the pleadings, concluding that the statute of limitations barred all claims. The Nelson Estate argued that the statute of limitations had not expired and that equitable estoppel or fraudulent concealment should prevent the statute of limitations defense.The Supreme Court of South Dakota reviewed the case and affirmed the circuit court's determination that the first six business interest claims accrued upon Dr. Nelson's death in 2013. However, the court reversed the dismissal of these claims because the circuit court did not address the Nelson Estate's defenses of equitable estoppel and fraudulent concealment. The court also reversed the dismissal of the tortious interference and civil conspiracy claims, as these claims arose from the 2022 sale of the business. Lastly, the court reversed the dismissal of the conversion claim, noting that the record did not establish when the conversion occurred or when the Nelson Estate became aware of it. The case was remanded for further proceedings. View "Nelson v. Tinkcom" on Justia Law

Golden View Ready-Mix, LLC (Golden View) supplied concrete to Grangaard Construction, Inc. (Grangaard) for a bridge project. Golden View alleged that Grangaard failed to pay for the concrete, breached the implied obligation of good faith and fair dealing, and committed fraud. A jury found in favor of Golden View on the breach of contract and good faith claims, awarding damages and punitive damages, but found no liability for fraud. Grangaard appealed the punitive damages award and the decision to submit the fraud issue to the jury.The Circuit Court of the First Judicial Circuit, McCook County, South Dakota, presided over the case. Grangaard moved for partial summary judgment on the fraud claim, arguing there was no independent tort duty outside the contract. The court denied this motion, allowing the fraud claim to proceed. During the trial, the court permitted the jury to consider punitive damages based on the breach of the implied obligation of good faith, despite Grangaard's objections.The Supreme Court of the State of South Dakota reviewed the case. The court determined that punitive damages are only recoverable for breaches of obligations not arising from a contract, as per SDCL 21-3-2. The court found that the implied obligation of good faith arises from the contract itself and does not constitute an independent tort that could support punitive damages. Consequently, the court vacated the punitive damages award. However, the court affirmed the lower court's judgment in all other respects, concluding that the error regarding punitive damages did not affect the jury's decision on the breach of contract and good faith claims. View "Goldenview Ready-Mix, LLC v. Grangaard Construction, Inc." on Justia Law

Calvin Berwald, operating Sokota Dairy, filed a lawsuit against Stan’s, Inc., a local feed mill, alleging breach of contract and breach of implied warranties. Berwald claimed that Stan’s prematurely canceled a soybean meal purchase agreement and sold him contaminated calf starter, resulting in the death of over 200 calves. Stan’s argued that the contract was canceled due to Berwald’s late payments and that the calf deaths were due to poor facilities and feeding practices.The Circuit Court of the Third Judicial Circuit in Jerauld County granted summary judgment in favor of Stan’s on the breach of contract claim, citing accord and satisfaction. The court found that Berwald’s acceptance and deposit of a check from Stan’s, which was intended to settle the dispute, discharged the claim. A jury trial on the breach of warranty claims resulted in a verdict that Stan’s breached the warranty of fitness for a particular purpose but awarded no damages to Berwald. The jury found against Berwald on the claims for breach of the implied warranty of merchantability and barratry.The Supreme Court of the State of South Dakota reviewed the case. The court affirmed the summary judgment, holding that Stan’s satisfied the requirements for accord and satisfaction under SDCL 57A-3-311. The court found no genuine issue of material fact regarding the good faith tender of the check, the existence of a bona fide dispute, and Berwald’s acceptance of the payment. The court also upheld the denial of Berwald’s motion for a new trial, finding no newly discovered evidence that would likely produce a different result and no prejudicial juror misconduct. The court concluded that the circuit court did not abuse its discretion in its rulings. View "Berwald V. Stan's, Inc." on Justia Law

The Supreme Court held that S.D. Codified Laws 58-29B-56 provides a state insurance liquidator an additional 180 days to provide a notice of a claim under a claims-made professional liability policy.The South Dakota Director of Insurance filed a petition for an order of liquidation of ReliaMax Surety Company (RSC), a subsidiary of ReliaMax Holding Company (RHC). The circuit court declared RSC to be insolvent and directed the company's liquidation. The state insurance liquidator (Liquidator) later commenced the underlying action against the directors and officers (D&O) of RSC and RHC. Under a settlement agreement, the Liquidator was granted a final judgment, agreeing not to execute upon and instead receiving an assignment of the D&Os' claims for coverage under a policy issued by SL Specialty. The Liquidator then brought this action against XL Speciality. At issue was the timeliness of the Liquidator's claim seeking D&O coverage. The district court certified questions of law to the Supreme Court. The Court held that section 58-29B-56 provides a state insurance liquidator an additional 180 days to provide notice of a claim under a claims-made professional liability policy. View "Deiter v. XL Specialty Insurance Co." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing this complaint alleging several breaches related to conduct allegedly occurring in connection with the ownership and operation of a pet grooming business, holding that several causes of action were improperly dismissed.The complaint in this case alleged claims for breach of fiduciary duty, breach of the duty of loyalty, breach of the duty of care, conversion, and unjust enrichment, and a separate cause of action for punitive damages. The circuit court dismissed the complaint in its entirety for failure to state a claim. The Supreme Court largely reversed, holding (1) Plaintiff properly instituted this action against Defendant; (2) the circuit court erred in dismissing the causes of action for breach of the duty of loyalty, breach of the duty of care, conversion, and unjust enrichment; and (3) Plaintiff's request for punitive damages was sufficiently pled. View "Mach v. Connors" on Justia Law

Robinson purchased grain bin monitoring equipment for his Spink County farm, financed through an Equipment Lease Agreement with Northland. Northland’s place of business is in Minnesota. The Lease included a forum selection clause requiring any suit filed by either party to be filed in Stearns County, Minnesota. After Robinson stopped making payments, Northland filed suit in Spink County, South Dakota, where Robinson resided. Robinson objected, claiming that he intended to pursue claims against Northland and others in Minnesota for the defective equipment. In granting Northland summary judgment., the circuit court treated Robinson’s objection as a question of venue and determined that Robinson failed to make a timely objection in Spink County.The South Dakota Supreme Court reversed and remanded, ordering the dismissal of the Spink County action. The court applied Minnesota law consistent with the Lease's choice of law provision and stated that the statutory venue provisions have no application to the question of the enforceability of the contractual forum selection clause. Robinson’s actions in responding to the suit do not support a waiver determination under the Rules of Civil Procedure. The Lease does not indicate that the forum selection clause was intended to solely benefit Northland, or that the mandatory language requiring “any suit by either of the parties” could be unilaterally waived. View "Northland Captial v. Robinson" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Defendants' 2013 motion to enforce a purported settlement agreement and to compel arbitration and dismissing Defendants' claim for unjust enrichment after a trial, holding that the circuit court did not err.Plaintiff brought suit against Defendants, his brothers, to dissolve their family partnership and asserting claims for breach of contract and breach of fiduciary duty. Defendants asserted multiple counterclaims based on Plaintiff's alleged misappropriation of partnership assets. This appeal concerned only the circuit court's denial of Defendants' motion to enforce the settlement agreement and to compel arbitration and the dismissal of Defendants' claim for unjust enrichment. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Defendants' motion to enforce the purported settlement agreement and to compel arbitration; and (2) did not err in denying Defendants relief on their claim for unjust enrichment. View "Paweltzki v. Paweltzki" on Justia Law

The Supreme Court dismissed this appeal seeking review of four adverse pretrial decisions after the circuit court granted summary judgment on some of the parties' claims, holding that accepting appellate jurisdiction would lead to piecemeal litigation of the myriad claims among the four parties.When one of three founding members of a cooperative grazing association died, his estate invoked a provision of the bylaws of the association to withdraw real estate that was previously contributed to the association and sell it to a third party. Another member objected, leading to this litigation. The circuit court granted summary judgment to the estate as to certain claims but did not determine all of the various claims among the parties. Two parties appealed, seeking review of four adverse pretrial decisions. The Supreme Court dismissed the appeal, holding that the justification for the S.D. Codified Laws 15-6-54(b) certification was not readily apparent from the record. View "Nelson v. Campbell" on Justia Law

The Supreme Court reversed the judgment of the circuit court granting partial summary judgment in favor of Smith Angus Ranch Inc. (SAR) on its claims for breach of fiduciary duty and self-dealing, holding that the circuit court erred by excluding extrinsic oral evidence in this case.In its complaint, SAR alleged that Travis Hurst, while serving as a director and officer of SAR, wrongfully acquired SAR assets and made improper purchases using SAR funds. After the court prohibited Hurst from presenting extrinsic oral evidence to show he was authorized to carry out the contested transactions, SAR moved for partial summary judgment on its claims for breach of fiduciary duty and self-dealing. The court granted partial summary judgment for SAR. The Supreme Court affirmed, holding (1) the circuit court erred by excluding extrinsic oral evidence; and (2) questions of fact existed precluding summary judgment. View "Smith Angus Ranch v. Hurst" on Justia Law