Justia South Dakota Supreme Court Opinion SummariesArticles Posted in Contracts
Mealy v. Prins
The Supreme Court reversed in part the circuit court's judgment granting Defendants summary judgment in part and, after a trial, entering a judgment consistent with the jury verdict, holding that a new trial on Plaintiffs' conversion and unjust enrichment claims was necessary. Plaintiffs loaned Defendants nearly $1.2 million, securing the loans with fifty-five promissory notes. Plaintiffs later sued Defendants for breach of contract, unjust enrichment, and conversion. Defendants counterclaimed for conversion and unjust enrichment. The circuit court granted Defendants summary judgment in part, dismissing forty-eight of the promissory notes as time barred and concluding that the related mortgage was unenforceable. After a trial, the jury returned a verdict for Plaintiffs on their breach of contract claim, rejected their claim for conversion, and awarded Defendants $135,000 on their conversion counterclaim. The jury then rendered an advisory verdict for Defendants as to the parties' competing claims for unjust enrichment. The Supreme Court reversed in part, holding that the circuit court (1) abused its discretion by giving a missing witness instruction at trial, (2) erred by allowing the jury to determine the date to begin calculating interest on the enforceable promissory notes, and (3) erred in allowing the jury to consider evidence of the time-barred notes when considering Plaintiffs' claims of unjust enrichment. View "Mealy v. Prins" on Justia Law
Healy v. Osborne
The Supreme Court affirmed the judgment of the trial court granting summary judgment in favor of Defendants and dismissing Plaintiff's suit claiming that he was financially damaged by Defendants' fraud and conspiracy and deprived of control over the family ranch, holding that the circuit court properly concluded that Plaintiff's suit was time barred. This case arose out of a family dispute over ownership and control of a family ranch. Plaintiff sued his mother, brothers, former attorney, and two business entities charging Defendants with, among other things, conversion, fraud, and conspiracy to commit fraud and requesting punitive and compensatory damages. The circuit court granted Defendants' motions for summary judgment on all claims, concluding that Plaintiff's claims were time barred. The circuit court then granted Defendants' motions for attorney fees, concluding that Plaintiff's lawsuit was frivolous and malicious. The Supreme Court affirmed, holding that the circuit court (1) properly concluded that Plaintiff's suit was time barred; and (2) did not abuse its discretion by awarding attorney fees to Defendants. View "Healy v. Osborne" on Justia Law
Stathis v. Marty Indian School
The Supreme Court affirmed the order of the circuit court dismissing this suit against Marty Indian School (MIS), a legal entity of the Yankton Sioux Tribe, for a lack of subject matter jurisdiction based on federal preemption, holding that the circuit court lacked subject matter jurisdiction to hear Plaintiff's claims against MIS. Plaintiff, the former high school principal at MIS, sued MIS and other involved parties after he was terminated. Plaintiff alleged claims for breach of contract, breach of settlement agreement, wrongful termination, libel, and slander, and requested punitive damages. The circuit court dismissed the complaint on the grounds of tribal sovereign immunity, immunity of tribal officials and employees, infringement of tribal sovereignty, and federal preemption. The Supreme Court affirmed the dismissal solely on a lack of subject matter jurisdiction based on federal preemption, holding that state court action in this dispute was preempted by federal law. View "Stathis v. Marty Indian School" on Justia Law
Institute of Range & American Mustang v. Nature Conservancy
The Supreme Court affirmed the decision of the dismissing The Institute of Range and the American Mustang’s (IRAM) lawsuit seeking to void a seventeen-year-old deed of conservation easement and to quiet title to its property, holding that the circuit court did not err in granting summary judgment in favor of The Nature Conservancy on IRAM’s claims. Specifically, the Court held (1) because the statute of limitations expired more than six years prior to IRAM’s suit, the circuit court did not err in granting The Nature Conservancy summary judgment on IRAM’s fraud claim; (2) summary judgment was properly granted on IRAM’s ultra vires claim and claim to vacate deed for no meeting of the minds; and (3) the circuit court did not err in granting The Nature Conservancy summary judgment on IRAM’s claim to vacate the deed for failure of consideration. View "Institute of Range & American Mustang v. Nature Conservancy" on Justia Law
Berbos v. Berbos
The Supreme Court affirmed the decision of the circuit court denying Appellants’ motion to intervene in a partnership dissolution action, holding that Appellants failed to meet the tripartite test necessary for intervention as a matter of right under S.D. Codified Laws 15-6-24(a)(2). Appellants entered into a farm lease/cash rent agreement with Berbos Farms General Partnership. Appellants sued Berbos Farms to recover unpaid cash rent under the lease for the years 2015. During discovery, Appellants learned that Joe and Lisa Berbos, partners in Berbos Farms, had filed a separate action to dissolve Berbos Farms. Seeking to preserve their right to payment of the 2015 cash rent in the event Berbos Farms was dissolved, Appellants move to intervene in the partnership dissolution action. The circuit court denied the motion. The Supreme Court affirmed, holding that because Appellants failed to show that the claim for unpaid cash rent might be impaired by the disposition of the partnership dissolution lawsuit, the circuit court correctly denied the motion to intervene under section 15-6-24(a)(2). View "Berbos v. Berbos" on Justia Law
Zochert v. Protective Life Insurance Co.
The Supreme Court affirmed the circuit court’s decision granting summary judgment in favor of Protective Life Insurance Company on Plaintiff’s complaint alleging breach of contract and bad faith, holding that there were no genuine issues of material fact indicating that Protective breached its contract with Plaintiff. Specifically, the Court held (1) Plaintiff’s claim that Protective breached the implied contractual duty of good faith and fair dealing was reviewable; (2) the circuit court did not err when it determined that Protective did not breach the implied contractual duty of good faith and fair dealing; and (3) the circuit court did not err in ruling that Protective did not commit bad faith in handling Plaintiff’s claims. View "Zochert v. Protective Life Insurance Co." on Justia Law
Huston v. Martin
The Supreme Court affirmed in part and reversed in part the circuit court’s dismissal of this challenge to a decedent’s pre-death conveyance, holding that Plaintiff may have an unjust enrichment claim against one of the defendants in this case. Plaintiff’s father, the decedent in this case, promised Plaintiff he would leave her half of his estate if Plaintiff conveyed considerable amounts of land to her father and nephew. The decedent, however, left Plaintiff only $30,000 in his will after conveying the vast majority of his multi-million-dollar estate to Plaintiff’s nephew. Plaintiff sued her nephew and the estate alleging fraud, contract, and unjust enrichment. The circuit court granted summary judgment for the defendants. The Supreme Court (1) affirmed the denial of the breach of contract claim, holding that this claim failed under S.D. Codified Laws 29A-2-514 because it was not evidenced in writing; (2) affirmed the denial of Plaintiff’s fraud claim, holding that S.D. Codified Laws 29A-3-803 barred this claim; and (3) reversed the circuit court’s grant of summary judgment on Plaintiff’s unjust enrichment claim against her nephew, holding that genuine issues of material fact existed precluding summary judgment on this claim. View "Huston v. Martin" on Justia Law
Domson, Inc. v. Kadrmas Lee & Jackson, Inc.
The Supreme court affirmed the judgment of the circuit court granting summary judgment in favor of Defendants in this action for summary judgment, holding that an exculpatory clause in a contract between the parties unambiguously insulated Defendants for liability in tort and contract for their good-faith acts and failures to act under the authority granted to them by the contract and contract documents. At issue was the enforceability of exculpatory clauses insulating a third party from claims of negligent design and negligent administration and interpretation of a contract. The Supreme Court held that Defendants, who were hired by the Oglala Sioux Tribe to design a road reconstruction project, were entitled to summary judgment where (1) Plaintiff failed to establish that the clause at issue contravened public policy; (2) Defendants established a prima facie case of good faith, and there was no material issue of fact in dispute on the issue of Defendants’ good-faith acts and failures to act in the interpretation and application of the contract documents; and (3) no genuine material issue existed for trial that Defendants’ design and drafting fell below a professional standard of care. View "Domson, Inc. v. Kadrmas Lee & Jackson, Inc." on Justia Law
ISG, Corp. v. PLE, Inc.
In this case asserting breach of contract and fraud, the Supreme Court reversed the order of the circuit court granting the motion filed by Portable Lift Equipment Inc. (PLE) for a new trial on the issue of damages, holding that the circuit court erred in concluding that there was insufficient evidence to support the compensatory awards. International Services Group Corp. (ISG) contracted with PLE to build two observation platforms for use by law enforcement at a festival held in Puerto Rico. PLE failed to deliver the agreed-upon platforms and instead delivered a contractually noncompliant platform. ISG sued PLE and its president. The jury found in favor of ISG and awarded both compensatory and punitive damages. PLE later filed a motion for a new trial. The circuit court granted a new trial on the issue of damages, expressing concern that it could not replicate the jury’s calculations, and denied the motion on the issue of liability. The Supreme Court reversed, holding that the compensatory damages awards provided by the jury could be explained by the evidence, and the compensatory damages did not impermissibly taint the punitive-damages awards. View "ISG, Corp. v. PLE, Inc." on Justia Law
Posted in: Contracts
Work v. Allgier
The Supreme Court reversed the judgment of the circuit court granted summary judgment for Debtor in this breach of contract case brought by Creditor to recover unpaid installments under a promissory note. In moving for summary judgment, Debtor relied on an acceleration provision in the promissory note, asserting that the statute of limitations had expired on Creditor’s claim six years after Debtor defaulted. The Supreme Court reversed the circuit court’s grant of summary judgment in favor of Debtor, holding that a material issue of fact was in dispute whether Debtor’s conduct following default warranted a different limitation period. View "Work v. Allgier" on Justia Law
Posted in: Contracts