Justia South Dakota Supreme Court Opinion Summaries

This dispute arose from Plaintiff’s purchase from David Bisson of seventy heifers whose health certifications were incorrect and origin could not be determined. As a result, the heifers had to be quarantined for approximately five months. Plaintiff sued Defendants, including Bisson, Mihm Transportation Co. and Paul Radloff, alleging fraudulent misrepresentation and deceit and civil conspiracy. The circuit court entered a default summary judgment against Bisson for fraudulent misrepresentation and deceit in the amount of $100,004 in actual damages and $1 million in punitive damages. After a trial on the remaining claims, the jury found in favor of Plaintiff on the civil conspiracy claim as to Mihm and Radloff. The Supreme Court affirmed, holding that the circuit court (1) did not err in failing to impose upon Bisson, Mihm, and Radloff joint and several liability for the totality of the summary judgment award, including punitive damages; and (2) did not err in denying Plaintiff’s motion for judgment as a matter of law against defendant Rod Spartz. View "Huether v. Bisson" on Justia Law

Clint Bowyer, a North Carolina resident, was a professional race car driver for NASCAR. Appellant was also a motorcycle enthusiast who often attended the motorcycle rallies in Sturgis, South Dakota. Kustom Cycles, Inc., a South Dakota corporation, agreed to customize a motorcycle for Bowyer. After Kustom Cycles delivered the motorcycle to Bowyer, it sent Bowyer a bill for the work in the amount of $30,788. Bowyer refused to pay the bill, insisting that the owner of the corporation proposed, and Bowyer performed, compensation in the form of promotions, endorsements, and special access to NASCAR events. Kustom Cycles filed a complaint against Bowyer for payment of the bill. Bowyer moved to dismiss for lack of personal jurisdiction. The circuit court denied the motion. The Supreme Court reversed, holding that Bowyer’s minimal contacts with South Dakota did not meet the “minimum contacts” required to satisfy the Due Process Clause, and Kustom Cycles did not meet its burden of establishing a prima facie case of personal jurisdiction over Bowyer. View "Kustom Cycles, Inc. v. Bowyer" on Justia Law

Terry and Cindy Leonhardt sued Terry’s father, Delbert Leonhardt, for specific performance of an oral lease and right of first refusal. The Leonhardts alleged that they had entered into an oral lease with Delbert whereby they would have the right to lease Delbert’s farmland during the lifetime of Delbert and his wife and that Delbert orally promised them a right of first refusal to purchase the farmland after he and his wife died. The Leonhardts claimed that Delbert breached the agreements when he gave Terry notice of his intent to terminate the Leonardts’ lease. On remand, the circuit court entered judgment against the Leonhardts, concluding that no credible evidence existed to support the existence of a lifetime lease or right of first refusal. The Supreme Court affirmed, holding that the circuit court did not clearly err when it ruled that the Leonhardts failed to meet their burden of proof that a lifetime lease and right of first refusal existed. View "Leonhardt v. Leonhardt" on Justia Law

Defendants, two individuals, worked as automobile salesman for two different dealerships. Defendants signed materially identical noncompete agreements during the course of their employments. Defendants later started their own automobile dealership, and Plaintiffs, their former employers, sued, seeking injunctions to enforce the agreements. The circuit court ruled that it would decide the requests for injunctions after a jury determined Defendants’ defenses. The jury found for Appellees on several of their defenses, and in accordance with the jury verdict, the circuit court denied injunctive relief. The Supreme Court reversed, holding that the circuit court improperly utilized a binding jury to determine equitable defenses without the consent of the parties. Remanded. View "Granite Buick GMC, Inc. v. Ray" on Justia Law

A.H. Meyer & Sons, Inc. produced honey and beeswax at a plant in Winfred, South Dakota. Barton Solvents, Inc. sold the heptane to A.H. Meyer that A.H. Meyer used in its beeswax rendering process. The heptane was manufactured by CITGO Petroleum Corporation. In 2009, A.H. Meyer suffered a heptane explosion at its plant. Nationwide Mutual Insurance paid for the damage. Nationwide subsequently filed suit seeking subrogation from Barton Solvents and CITGO on causes of action alleging strict liability, negligence, and breach of express and implied warranties. All theories were premised on the theory that Defendants failed adequately to warn of heptane’s dangers. The circuit court granted summary judgment for Defendants. The Supreme Court affirmed, holding that summary judgment was appropriate because no material issues of disputed fact existed with respect to the adequacy of the warnings. View "Nationwide Mut. Ins. Co. v. Barton Solvents, Inc." on Justia Law

Kreisers Inc., a Subchapter S corporation, hired First Dakota Title to assist it with a like-kind property exchange in order to receive tax deferred benefits under 26 U.S.C. 1031. The like-kind exchange partially failed. Kreisers subsequently sued First Dakota for negligence and negligent misrepresentation. The circuit court rejected Kreiser’s negligent misrepresentation claim but determined that First Dakota was negligent in assisting Kreisers with the exchange. The Supreme Court affirmed, holding that the circuit court (1) did not err in applying tort law rather than contract law to determine the duty that First Dakota owed to Kreisers; (2) did not err in concluding that Kreisers was not contributorily negligent; and (3) did not err in its calculation of damages. View "Kreisers Inc. v. First Dakota Title Ltd. P’ship" on Justia Law

Shane Liebig testified that he and Edward Kirchoff orally agreed that Kirchoff would purchase real property and later convey it to Liebig on certain terms. When Kirchoff did not convey the property to Liebig, Liebig sued for enforcement of the alleged purchase agreement and for fraud and deceit. Kirchoff counterclaimed, alleging unjust enrichment/quantum meruit. After a bench trial, the circuit court ruled that Liebig failed to establish a contractual right to purchase the property. A jury decided the remaining claims. The jury awarded Liebig compensatory and punitive damages on his fraud-and-deceit claim and awarded Kirchoff damages on his unjust enrichment/quantum meruit claim. The Supreme Court affirmed in part and reversed in part, holding (1) the circuit court did not clearly err in finding that the parties never reached a meeting of the minds as to the material terms of the contract; (2) the circuit court did not err in denying Kirchoff’s motion for summary judgment on Liebig’s fraud-and-deceit claim; and (3) the jury’s award of damages on the fraud-and-deceit claim exceeded the amount Liebig was entitled to claim. Remanded for a new trial on damages related to Liebig’s fraud-and-deceit claim. View "Leibig v. Kirchoff" on Justia Law

During their marriage, Brian Shabino and Sandra Wichman borrowed money from Sandra’s mother, Mary Ann Wichman, to use as a down payment on the purchase of their home. When Sandra and Brian divorced in 2003, the divorce decree apportioned to Brian the marital home as well as the remaining debt to Mary Ann. Brian failed to repay Mary Ann, In 2012, Mary Ann brought suit for breach of contract, unjust enrichment, and enforcement of the divorce decree. The circuit court concluded that a portion of Mary Ann’s breach of contract claim was barred by the statute of limitations and that Mary Ann could not enforce the terms of the divorce decree. The Supreme Court affirmed, holding (1) the circuit court did not err in determining that Mary Ann could not enforce the divorce decree; and (2) the circuit court did not err in ruling that Mary Ann could not recover the entirety of the debt under the statute of limitations. View "Wichman v. Shabino" on Justia Law

After Mary Lou Fox died, Plaintiff, Mary Lou's daughter and the administratrix of Mary Lou's estate, sued Mary Lou's former husband, Robert Fox. Plaintiff alleged that Mary Lou jointly owned 960 acres of farmland with Robert, that Robert deprived Mary Lou of her ownership interest in the land, and that Plaintiff was thereby deprived of an inheritance from Mary Lou. The circuit court granted summary judgment to Robert, concluding that Mary Lou had no ownership interest in the 960 acres. The Supreme Court affirmed, holding that each cause of action brought by Plaintiff failed because Mary Lou had no claim to a right of ownership in the 960 acres and Plaintiff had no authority supporting her claims. View "Niesche v. Wilkinson" on Justia Law

Christine and David Colburn leased property from Robert Hartshorn and agreed to care for Hartshorn's cattle. Neither the terms of the cattle care agreement or the lease agreement were reduced to writing. After a dispute, the Colburns served on Hartshorn an agister's lien for caring for Hartshorn's cattle. The Colburns also brought an action to recover amounts due for their care of Hartshorn's cattle and to foreclose the lien. Ultimately, the Colburns received a court order to sell the calves. The circuit court ruled that the Colburns were entitled to one half the net calf sale proceeds from the sale but found the agister's lien invalid under the terms of the parties' implied contract because the cattle were cared for on Hartshorn's land and not the Colburns' land. The Supreme Court reversed, holding that nothing in the state's laws governing agister's liens defeats their validity when cattle are entrusted to a caretaker on the cattle owner's land. Remanded.View "Colburn v. Hartshorn" on Justia Law