Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court in favor of Prussman Contracting, Inc., holding that the court did not abuse its discretion.Dennis Sedlacek commenced this suit against Prussman, alleging general negligence and failure to train and supervise its employees. Sedlacek sought damages for injuries he allegedly sustained while repairing a crane owned by Prussman. The jury returned a general verdict in favor of Prussman. On appeal, Sedlacek argued that he was prejudiced by the court's rulings restricting his ability to argue that Prussman violated Occupational Health and Safety Administration (OSHA) standards. The Supreme Court affirmed, holding that even if this restriction was outside of the circuit court's range of permissible choices, Sedlacek could not establish that the error produced the adverse verdict. View "Sedlacek v. Prussman Contracting, Inc." 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 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

In this personal injury action, the Supreme Court affirmed the judgment of the circuit court in favor of Plaintiff, holding that the circuit court did not abuse its discretion in denying Defendants' motion to exclude testimony from Plaintiff's medical providers regarding the extent and permanency of his injuries and that the jury's verdict was not the result of passion or prejudice.Specifically, the Court held (1) the circuit court properly exercised its discretion in allowing Plaintiff's treating providers to testify about the permanency of his injuries, and the court's decision to allow the undisclosed opinions by Plaintiff's regular medical provider about the impact of Plaintiff's injuries did not create prejudice sufficient to warrant reversal; and (2) the evidence presented to the jury supported its verdict and failed to support Appellants' claim that the jury acted with passion or prejudice. View "Weber v. Rains" on Justia Law

The Supreme Court affirmed the circuit court's order denying State Farm Mutual Auto Insurance Company's motion for a new trial after a jury returned a general verdict in favor of Giyo Miranda and denying State Farm's request for subrogation recovery against Miranda, holding that State Farm was not prejudiced by the court's instructions to the jury on the sudden emergency doctrine.Giyo Miranda was involved in a head-on collision with another vehicle driven by Loyd Nielson after Miranda lost control of his vehicle. State Farm, Nielson's insurer, pursued subrogation recovery against Miranda, but the jury returned a general verdict in favor of Miranda. State Farm filed a motion for a new trial, which the circuit court denied. The Supreme Court affirmed, holding that State Farm failed to establish any prejudice from the circuit court's instructions and that the court was unable to exercise meaningful appellate review on the merits of State Farm's claims. View "State Farm Mutual Automobile Insurance Co. v. Miranda" on Justia Law

In response to a certified question from the district court the Supreme Court declined to recognize a cause of action for tortious interference with inheritance or expectancy of inheritance, holding that adopting such a cause of action and expanding tort liability to the already existing remedies available to estate litigants in South Dakota was unnecessary.Plaintiff filed a complaint against Defendant, his sister, alleging claims for tortious interference with inheritance or expectancy of inheritance, breach of fiduciary duty, and negligence. The district court dismissed the negligence and breach of fiduciary duty claims then certified to the Supreme Court the question of whether South Dakota recognizes tortious interference with inheritance or expectancy of inheritance. The Supreme Court answered the question in the negative after considering the decisions from other jurisdictions and other policy considerations under existing law in the State, holding that Plaintiff failed to convince the Court that existing remedies were inadequate. View "Briggs v. Briggs" on Justia Law

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

The Supreme Court reversed the order of the circuit court granting the motion to dismiss filed by Waste Connections of South Dakota, Inc. on Kimberlynn Cameron's complaint, holding that Cameron properly initiated suit against Waste Connections prior to the expiration of the statute of limitations, and therefore, the circuit court erred when it dismissed the suit.Cameron brought a personal injury suit against Jason Osler after she was injured in a car accident. Thereafter, Cameron filed an amended complaint adding a claim for vicarious liability and naming Waste Connections, Osler's employer, as a defendant. Cameron, however, failed timely to serve Osler, and he was dismissed from the suit. In its motion to dismiss Waste Connections argued that Cameron's failure to timely serve Osler precluded suit against Waste Connections. The circuit court granted the motion to dismiss. The Supreme Court reversed, holding that the dismissal of Osler did not preclude suit against the employer for vicarious liability. View "Cameron v. Osler" on Justia Law