Justia South Dakota Supreme Court Opinion Summaries

In this insurance dispute arising from an employee's death, the Supreme Court remanded the determination that the employer's insurer providing underinsured motorist coverage and workers' compensation insurance was entitled to a lien on a portion of settlement proceeds received by the estate, holding that, given a lack of factual findings, there was no way to evaluate whether the court clearly erred in its assessment of the various factors impacting an equitable allocation.Charles Luze died in a work-related accident. His employer paid his wife, Jeanette Luze, workers' compensation benefits. Jeanette, as the representative of Charles's estate, then brought suit against the negligent driver and settled the claim. The estate also settled a claim against the New FB's insurer providing underinsured motorist coverage, Zurich American Insurance Company, which was also New FB's workers' compensation carrier. The circuit court determined that Zurich was entitled to a statutory workers' compensation lien on fifty percent of the settlement proceeds received by the estate and was able to subrogate against its own settlement payment of underinsured benefits. The Supreme Court remanded in part, holding (1) this Court was unable meaningfully to review the circuit court's allocation determination; and (2) the circuit court properly allowed Zurich to subrogate against the amount it paid in underinsured motorist benefits. View "Luze v. New FB Co." on Justia Law

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

The Supreme Court reversed the circuit court's award of employee benefits to Plaintiff, holding that Plaintiff was not entitled to employee benefits under the City of Edgemont's Personnel Manual.Plaintiff sued the City of Edgemont alleging that he was owed employee benefits under the Manual. The circuit court found that Plaintiff was a City employee as of December 3, 2012 but only awarded employee benefits under the Manual after Plaintiff was appointed City Engineer/Code Officer on May 6, 2014. The Supreme Court affirmed in part and reversed in part, holding (1) the circuit court correctly denied Plaintiff any additional employee benefits under the Manual from December 3, 2012 to May 6, 2014; (2) the circuit court erred in granting benefits under the Manual from May 6, 2014 through May 5, 2015 because, as a temporary or seasonal employee, Plaintiff did not qualify for the benefits afforded to regular full-time or part-time employees; and (3) Plaintiff was not entitled to attorney fees because he did not prevail on his wage claim. View "Koopman v. City Of Edgemont" on Justia Law

The Supreme Court reversed the judgment of the circuit court in favor of Appellee in this workers' compensation case, holding that an error led to the exclusion of relevant evidence and incorrect jury instructions that impacted the jury's verdict, which prejudiced Appellants.Fern Johnson sued her former employer and its workers' compensation carrier (collectively, Appellants) alleging bad faith and conversion based on their denial of previously ordered workers' compensation medical benefits. A jury returned a verdict for Johnson. The Supreme Court reversed and remanded the case for a new trial, holding (1) the circuit court did not err when it concluded that Appellants' legal obligation to pay Johnson's benefits was not fairly debatable; but (2) the circuit court erred when it determined that the lack of a reasonable basis to deny benefits necessarily impacted the jury's consideration of the separate bad faith element concerning Appellants' knowledge. View "Johnson v. United Parcel Service, Inc." on Justia Law

The Supreme Court affirmed the order of the circuit court granting summary judgment for Hospital on Nurse's claims for wrongful discharge, breach of contract, and defamation, holding that summary judgment was proper.Hospital terminated Nurse after it discovered errors in Nurse's documentation of controlled substances and Nurse's inability to account for controlled substances revamped from the dispensing system. Nurse brought suit against Hospital alleging several claims. The circuit court granted summary judgment for Hospital on all claims. The Supreme Court affirmed, holding that summary judgment was properly granted in favor of Hospital. View "Henning v. Avera McKennan Hospital" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Plaintiff's request for attorney fees under S.D. Codified Laws 60-11-24 after Plaintiff prevailed in an action seeking unpaid wages, holding that because this case was removed for a bench trial section 60-11-24 did not apply and Plaintiff was not entitled to recover attorney fees.After Defendant fired Plaintiff, Plaintiff brought an action in small claims court for unpaid wages. Defendant removed the action to circuit court, which ruled in favor of Plaintiff. Plaintiff requested attorney fees under section 60-11-24. The circuit court denied the request because the removal statute referenced in section 60-11-24 had been repealed. The Supreme Court affirmed, holding (1) the circuit court did not err in concluding that it could not award reasonable attorney fees under section 60-11-24 because of the repeal of S.D. Codified Laws 15-39-59; and (2) while attorney fees remain recoverable under section 60-11-24 for small claims cases removed to circuit court for a jury trial, this case was removed for a bench trial. View "Goin v. Houdashelt" on Justia Law

The Supreme Court reversed the judgment of the circuit court affirming the decision of the South Dakota Department of Labor dismissing Plaintiff's petition seeking workers' compensation benefits for lack of prosecution, holding that Plaintiff engaged in activity within a year before the motion to dismiss was filed.Plaintiff filed a petition with the Department seeking disability benefits and medical expenses arising from her workplace injury. Eventually, Employer/Insurer filed a motion to dismiss for lack of prosecution under ARSD 47:03:01:09, asserting that there had been no activity for at least one year and that Plaintiff had failed to show good cause for the delay. The Department granted the motion to dismiss. The Supreme Court reversed, holding that the Department abused its discretion in dismissing the appeal because its decision was based upon its erroneous conclusion that Plaintiff's participation in a vocational rehabilitation program was not "activity" under ARSD 47:03:01:09. View "Laplante v. GGNSC Madison, S.D." on Justia Law

The Supreme Court affirmed the judgment of the circuit court affirming the decision of the Department of Labor to award benefits to James Bonebright's widow, Stephanie, after Bonebright died from injuries he sustained in a work-related accident, holding that the workers' compensation claim was not precluded by willful misconduct.Bonebright's employer, the City of Miller, and the City's workers' compensation provider denied workers' compensation liability on the ground that Bonebright had engaged in willful misconduct. Stephanie petitioned the Department for medical and funeral expenses along with indemnity benefits as a surviving spouse. The Department awarded Stephanie benefits, concluding that although Bonebright had engaged in willful misconduct, the City had not established that Bonebright's failure to follow safety precautions was a proximate cause of his injury and death. The circuit court reversed the Department's willful misconduct finding. The Supreme Court affirmed, holding that Stephanie's claim was not precluded by willful misconduct because the City did not demonstrate bona fide enforcement of its safety rules. View "Bonebright v. City Of Miller" on Justia Law

The Supreme Court affirmed the order of the circuit court affirming the decision of the Department of Labor determining that Appellant's knee surgery and related treatment were not compensable, holding that the Department did not err when it concluded that Appellant's work-related injury, in combination with his preexisting condition, did not remain a major contributing cause of his disability, impairment, or need for treatment.Appellant injured his left knee while working for Appellee. Appellee denied liability for Appellant's total knee replacement surgery and post-operative treatment. The Department found the work-related injury neither contributed independently nor was a major contributing cause of Appellant's need for surgery. The circuit court affirmed. The Supreme Court affirmed, holding that Appellant failed to prove causation under either S.D. Codified Laws 62-1-1(7)(b) or S.D. Codified Laws 62-1-1(7)(c). View "Armstrong v. Longview Farms, LLP" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of Mid-Century Insurance Company and dismissing Christina Blanchard's bad-faith complaint, holding that the circuit court properly granted summary judgment for Mid-Century.In her complaint, Blanchard alleged that Mid-Century pursued a "baseless and meritless appeal" from a decision of the South Dakota Department of Labor awarding Blanchard workers' compensation benefits. On appeal, Blanchard argued, among other things, that the circuit court erred in excluding evidence under the litigation conduct rule. The Supreme Court concluded that the circuit court's exclusion of the evidence under the litigation conduct rule was determinative of the appeal, and therefore it was unnecessary to discuss Blanchard's other claims of error, holding that the circuit court properly excluded the evidence and properly granted summary judgment based upon the other undisputed facts in the record. View "Blanchard v. Mid-Century Insurance Co." on Justia Law