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

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

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

Joshua Lapin, acting pro se, filed a complaint against Zeetogroup, LLC and “John Doe Sender” alleging 46 violations of SDCL 37-24-47, which prohibits misleading, falsified, or unauthorized spam emails. Lapin claimed he received these emails between June 15 and July 25, 2021, at his email address, which he argued was a “South Dakota electronic mail address.” The circuit court dismissed Lapin’s claims on summary judgment, concluding that Lapin was not a “resident of this state” during the time he received the emails and, therefore, could not prove his email address was a “South Dakota electronic mail address” as required by SDCL 37-24-47. Lapin appealed.The Circuit Court of the Second Judicial Circuit, Minnehaha County, South Dakota, denied Lapin’s motion for partial summary judgment and granted Zeetogroup’s motion for summary judgment. The court found that Lapin was not a resident of South Dakota when he received the emails because he was traveling internationally as a “digital nomad” and was not physically present in the state. The court also held that SDCL 37-24-41(14) does not impose a durational residency requirement and that Lapin could sue over emails received after he became a physical resident of South Dakota.The Supreme Court of the State of South Dakota affirmed the circuit court’s decision. The court held that the term “resident” in SDCL 37-24-41(14)(c) requires actual residency, not just legal residency or domicile. The court concluded that Lapin’s 30-day stay in an Airbnb in South Dakota and his subsequent travels did not establish him as a resident of South Dakota during the time he received the emails. Therefore, Lapin was not entitled to the protections of SDCL 37-24-47. View "Lapin v. Zeetogroup" on Justia Law

Jessica Paulsen experienced severe bleeding after giving birth on December 13, 2021, at Avera McKennan Hospital. Dr. Amber Saloum performed a hysterectomy and another surgery on December 14, 2021, to stop the bleeding. Paulsen later claimed she did not consent to the hysterectomy and filed a lawsuit against Avera McKennan, Dr. Saloum, and unnamed parties on December 15, 2023. The defendants moved for summary judgment, arguing that Paulsen's claims were barred by the two-year repose period under SDCL 15-2-14.1.The Circuit Court of the Second Judicial Circuit, Minnehaha County, South Dakota, granted the defendants' motion for summary judgment, concluding that Paulsen's lawsuit was filed outside the two-year repose period. Paulsen appealed the decision, arguing that the repose period should be calculated as 730 days and that she should have been allowed additional discovery to potentially establish a continuing tort.The Supreme Court of the State of South Dakota reviewed the case de novo. The court held that a "year" is defined as a "calendar year" under SDCL 2-14-2(36), meaning the repose period ends at the exact moment the start date reoccurs on the calendar. Therefore, the two-year repose period began on December 15, 2021, and ended on December 14, 2023. Since Paulsen filed her lawsuit on December 15, 2023, it was one day too late.The court also found that Paulsen's request for additional discovery was speculative and did not demonstrate how further discovery would reveal facts essential to opposing the summary judgment. Consequently, the court affirmed the circuit court's decision to grant summary judgment in favor of the defendants. View "Paulsen v. Mckennan" on Justia Law

A widow, Lori Olson, individually and as the personal representative of her deceased husband Scott Olson's estate, filed a lawsuit against Huron Regional Medical Center (HRMC), Dr. William Miner, and Thomas Miner, a physician’s assistant, alleging negligence, wrongful death, loss of consortium, intentional infliction of emotional distress, civil conspiracy, and fraudulent concealment. Scott Olson died at HRMC in January 2020 under the care of Dr. Miner and Thomas Miner. Lori Olson initiated the lawsuit in September 2021.The Circuit Court of the Third Judicial Circuit in Beadle County, South Dakota, denied Dr. Miner’s motion to dismiss for insufficient service of process but later granted the defendants' motions to dismiss for failure to prosecute. Lori Olson appealed the dismissal, and Dr. Miner filed a notice of review challenging the denial of his motion to dismiss for insufficient service.The Supreme Court of South Dakota reviewed the case and found that there was verifiable record activity within the year prior to the defendants’ motion to dismiss, including efforts to compile medical records and communication between the parties. The court concluded that the Circuit Court erred in dismissing the case under SDCL 15-11-11 for lack of prosecution, as there was sufficient activity to move the case forward. Additionally, the court found that the delays in the case did not rise to the level of egregiousness required for dismissal under Rule 41(b) and that the Circuit Court did not consider less severe sanctions before dismissing the case.The Supreme Court of South Dakota reversed the Circuit Court’s decision to dismiss the case for failure to prosecute and affirmed the denial of Dr. Miner’s motion to dismiss for insufficient service of process, concluding that Dr. Miner was properly served. View "Olson v. Huron Regional Medical Center, Inc." on Justia Law

In 2020, Cody Sturzenbecher and his mother, Judy Sturzenbecher, entered into a series of transactions with Sioux County Ranch, LLC (Sioux County) related to the purchase of their family farm from a trust. Judy bought the farm using a loan from Sioux County, then sold the property to Sioux County, which leased it to Cody. The lease included an option for Cody to purchase the property. Cody defaulted on the lease, leading Sioux County to terminate the lease and list the property for sale.The Sturzenbechers sought declaratory and injunctive relief, arguing that Judy’s conveyance of the farm to Sioux County created an equitable mortgage rather than an absolute sale. The Circuit Court of the First Judicial Circuit in Turner County, South Dakota, granted the Sturzenbechers’ request for a preliminary injunction and denied Sioux County’s motion for judgment on the pleadings. Sioux County appealed both decisions.The Supreme Court of the State of South Dakota reviewed the case and affirmed the lower court’s decisions. The court concluded that the arrangement between the Sturzenbechers and Sioux County was intended as a financing agreement rather than an absolute sale. The court found that the agreements between the parties were unambiguous but unenforceable as an absolute sale due to public policy favoring a mortgagor’s right of redemption. The court held that the Sturzenbechers were likely to succeed on their equitable mortgage claim and that the circuit court did not abuse its discretion in granting the preliminary injunction. The court also affirmed the denial of Sioux County’s motion for judgment on the pleadings, finding that the Sturzenbechers had pled sufficient facts to support their claim. View "Sturzenbecher v. Sioux County Ranch" on Justia Law