Justia South Dakota Supreme Court Opinion Summaries

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

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

Dakota Bay, LLC owns property adjacent to McCook Lake in Union County, South Dakota, and planned to construct a canal connecting its land to the lake. To facilitate this, Dakota Bay’s owner, Michael Chicoine, applied for a shoreline alteration permit and a water permit to use an existing irrigation well to fill and maintain the canal. The McCook Lake Recreation Area Association, which holds a permit to pump water from the Missouri River into McCook Lake, opposed the project. The Association argued that constructing the canal would require a permit to appropriate water from McCook Lake and that the canal would increase water loss from the lake, potentially impairing the Association’s ability to maintain lake levels.The South Dakota Department of Agriculture and Natural Resources Water Management Board held hearings and ultimately denied the Association’s petition for a declaratory ruling, finding that the canal’s construction would not constitute an appropriation of water from McCook Lake. The Board also granted Dakota Bay’s application to use well water for the canal, finding that unappropriated water was available, the use was beneficial and in the public interest, and that it would not unlawfully impair existing water rights. The Association appealed both decisions to the Circuit Court of the First Judicial Circuit, which affirmed the Board’s rulings and also upheld the Board’s decision to quash subpoenas issued by the Association.On further appeal, the Supreme Court of the State of South Dakota affirmed the circuit court’s decisions. The Court held that constructing the canal would not result in an appropriation of water from McCook Lake and thus did not require a water appropriation permit. The Court also held that Dakota Bay’s proposed use of well water for the canal was a beneficial use in the public interest and that the Board did not abuse its discretion in quashing the subpoenas, clarifying that administrative proceedings are governed by the Administrative Procedures Act, not the rules of civil procedure. View "Mccook Lake Recreation Area V. Dakota Bay, LLC" on Justia Law

Three landowners in Roberts County, South Dakota, own agricultural properties encumbered by perpetual federal wetlands reserve easements, which severely restrict agricultural and other uses of the land. After the previous owner’s death, the properties were appraised at $897 per acre in 2017 but ultimately sold to the current landowners for about $128 per acre in 2019. In 2023, the county’s Director of Equalization assessed the properties using a statutory productivity-based method, resulting in values of $2,255.54 and $1,678.77 per acre, far exceeding the purchase price and prior appraisal. The landowners did not dispute the statutory method’s application but argued that the resulting assessments exceeded the properties’ actual value, violating the South Dakota Constitution.The landowners appealed the assessments through the local and county boards of equalization, both of which affirmed the Director’s valuations. They then appealed to the Office of Hearing Examiners (OHE), where an administrative law judge (ALJ) found the landowners’ witnesses—two real estate brokers—credible in their testimony that the easements significantly reduced the properties’ market value. However, the ALJ concluded she lacked authority to decide the constitutional issue and affirmed the assessments, finding the landowners had not rebutted the presumption of correct statutory procedure. The Circuit Court of the Fifth Judicial Circuit affirmed, holding that only a certified appraiser’s opinion could rebut the presumption of correctness and that the brokers’ opinions and the 2017 appraisal were insufficient.The Supreme Court of the State of South Dakota reversed and remanded. It held that neither the South Dakota Constitution nor state law requires a certified appraiser’s opinion to establish actual value for tax purposes; credible testimony from any qualified witness suffices. The Court further held that the landowners presented sufficient credible evidence that the assessments exceeded actual value. The case was remanded for a factual finding of actual value based on the existing record. View "Pallansch v. Roberts County" on Justia Law

A woman was injured while running along a city road when she stepped off the roadway to avoid traffic and her foot became lodged in a metal culvert that was partially exposed in a roadside ditch. The culvert had been installed by the city as part of improvement projects in the mid-1990s, and there were no sidewalks in the area. The woman suffered a sprained ankle and a significant laceration that required medical treatment. She alleged that the city failed to maintain the public right-of-way, leaving the culvert uncapped and exposed, and did not provide adequate inspection, maintenance, or warnings.After the incident, the city admitted responsibility for maintaining public rights-of-way and acknowledged that its maintenance practices were primarily complaint-driven, with no routine inspections or written policies for culvert maintenance. The city stated that it had not received complaints about the culvert before the accident and that, after being notified of the incident, it inspected and repaired the culvert by removing the damaged end section.The Circuit Court of the Fourth Judicial Circuit granted summary judgment in favor of the city on all claims, holding that the city owed no common law duty of care, that the plaintiff failed to show the culvert was damaged as required under the relevant statute (SDCL 31-32-10), and that the nuisance and gross negligence claims were barred or unsupported.The Supreme Court of the State of South Dakota reviewed the case de novo. It held that there were genuine issues of material fact as to whether the culvert was damaged and whether the city should have discovered the damage, making summary judgment on the negligence claim improper. However, the court affirmed summary judgment for the city on the nuisance and gross negligence claims, finding them barred by statutory exemptions and insufficient evidence, respectively. The court thus reversed in part and affirmed in part. View "Mahmoudi v. City Of Spearfish" on Justia Law

A state-operated university in South Dakota, facing increased demand for student housing, entered into a series of lease agreements with a local housing commission beginning in 2000. The commission constructed and financed two apartment buildings, leasing them to the university with an option for the university to purchase the property. The original 2000 lease included a provision for a reserve account, funded by any excess between actual debt service and lease payments, which would be disbursed to the university if it exercised its purchase option. Over the years, the parties executed new leases in 2011, 2014, and 2017, each with different terms and none referencing the reserve account provision from the 2000 lease. In 2020, the university notified the commission of its intent to purchase the property, leading to disputes over the purchase price and whether the university was entitled to a credit from a reserve account that no longer existed.The Circuit Court of the Third Judicial Circuit, Lake County, South Dakota, granted partial summary judgment in favor of the university, holding that all the leases should be read as a single, continuous contract, thereby extending the reserve account obligation from the 2000 lease into subsequent agreements. The court also interpreted the purchase price provision to refer to the original construction mortgage, not any refinanced debt, and determined the university was entitled to a refund after calculating the buy-out amount. The commission’s motion for reconsideration was denied, and final judgment was entered for the university.The Supreme Court of the State of South Dakota reversed and remanded. It held that the leases were separate agreements, not a single continuous contract, and that the reserve account obligation from the 2000 lease did not carry forward. The court further held that the buy-out price should be based on the balance of the mortgage existing at the time the purchase option was exercised, including any refinanced debt, not just the original mortgage. The circuit court’s judgment was vacated. View "S.D. Board Of Regents v. Madison Housing" on Justia Law

Rodney Alexander and Steve Hobart entered into an agreement granting Alexander a right of first refusal to purchase Steve’s cattle and to have Steve’s national forest livestock grazing permit transferred to him. An addendum later clarified that the agreement extended to Steve’s son, Nick. Years later, Nick sold the cattle and transferred the permit to a third party without notifying Alexander, who then sued for breach of contract and fraud. The defendants moved for judgment on the pleadings, arguing the contract was void due to impossibility of performance or because it was for an unlawful object, and that the right of first refusal was an unreasonable restraint on property alienation.The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, granted the motion, ruling the contract void for impossibility of performance. Alexander appealed, asserting the court erred in its conclusion. Nick, through notice of review, sought to challenge the court’s ruling that the right of first refusal was not an unreasonable restraint on alienation.The Supreme Court of the State of South Dakota reviewed the case de novo. It found that the contract did not require the Hobarts to transfer the permit directly, but rather that the purchase was contingent on the USFS transferring the permit to Alexander. The court concluded that the contract was not void for impossibility of performance. Additionally, the court affirmed the lower court’s ruling that the right of first refusal was not an unreasonable restraint on alienation, considering the purpose, price, and duration of the agreement, and the mutual consent of the parties.The Supreme Court reversed the circuit court’s order and judgment, remanding the case for further proceedings. View "Alexander v. Estate Of Hobart" on Justia Law

The case involves a dispute over the South Dakota Department of Corrections' (DOC) decision to purchase state-owned agricultural land in Lincoln County for a new men's state prison, authorized by House Bill 1017 (HB 1017). The plaintiffs, a group of private individuals and a non-profit corporation, sought declaratory and injunctive relief against the State of South Dakota, the DOC, and the DOC Secretary, arguing that the State must comply with local zoning regulations, which do not permit a prison in an agricultural district without a conditional use permit or rezoning.The Circuit Court of the Second Judicial Circuit in Lincoln County dismissed the plaintiffs' action. The court found that only two plaintiffs had standing based on alleged property value decreases. However, it dismissed the case on the grounds of sovereign immunity and preemption, determining that the DOC's actions were discretionary and that state law preempted local zoning regulations.The South Dakota Supreme Court reviewed the case and affirmed the lower court's dismissal. The Supreme Court held that the plaintiffs lacked a justiciable claim of right to enforce the local zoning ordinance against the State. The court emphasized that the Declaratory Judgments Act does not create substantive rights and that the plaintiffs failed to identify any statutory or other legal authority granting them a private right to enforce the zoning ordinance. Consequently, the case was deemed non-justiciable, and the court did not address the merits of the sovereign immunity and preemption claims. View "Jensen v. Dept Of Corrections" on Justia Law

Bighorn Construction, LLC (Bighorn) and JED Spectrum, Inc. (JED) filed mechanic’s liens against property owned by Keith Stoakes, seeking to foreclose on the liens. Stoakes denied the validity of the liens and counterclaimed for slander of title against both companies, and for breach of contract, promissory estoppel, and fraud against JED. After a bench trial, the circuit court denied Bighorn’s and JED’s claims for lien foreclosure and ruled in favor of Stoakes on his slander of title claims, awarding him $252,225.27 in damages and $33,394.20 in attorney fees. The court denied relief on the remaining claims.The circuit court found that Bighorn had no reasonable grounds to file the lien after receiving a check for full payment, and that JED’s lien was untimely and insufficiently itemized. The court also found that Stoakes reasonably relied on JED’s promise of a shared well system, awarding him damages for promissory estoppel. However, the court later reversed its decision on the promissory estoppel claim and reduced the attorney fee award accordingly.The Supreme Court of South Dakota reviewed the case. It reversed the circuit court’s ruling on the slander of title claims, finding insufficient evidence to prove that Jerry, acting on behalf of Bighorn and JED, knew or recklessly disregarded the falsity of the liens. The court affirmed the denial of Stoakes’s promissory estoppel claim, concluding that Stoakes did not suffer substantial economic detriment. The court also affirmed the attorney fee award of $33,394.20 to Stoakes, as it was within the court’s discretion under SDCL 44-9-42. View "Jed Spectrum, Inc. v. Stoakes" on Justia Law

Tom Smith Masonry (Smith Masonry) and WIPI Group USA, Inc. (WIPI) entered into a contract for Smith Masonry to construct a fence on WIPI’s property. After completing most of the work, Smith Masonry requested final payment, which WIPI withheld due to a dispute over the installation of a gate operator. Smith Masonry filed a mechanic’s lien and subsequently a lawsuit to foreclose on the lien, seeking the unpaid balance. WIPI counterclaimed for breach of contract and other issues, seeking damages for alleged faulty workmanship.The Circuit Court of the Second Judicial Circuit, Lincoln County, South Dakota, denied relief to both parties, finding that Smith Masonry’s work was defective and that WIPI’s damages were not established with exactitude. Smith Masonry appealed, and the South Dakota Supreme Court reversed and remanded, directing the lower court to enter a judgment of foreclosure in favor of Smith Masonry for the full amount of the lien and to reconsider Smith Masonry’s request for attorney fees.On remand, the circuit court entered a judgment in favor of Smith Masonry on the lien but denied the request for attorney fees. Smith Masonry appealed again. The South Dakota Supreme Court found that the circuit court violated the law of the case doctrine by revisiting issues already settled in the first appeal and by speculating on what might have occurred had the trial resumed. The Supreme Court also held that the circuit court abused its discretion by denying attorney fees based on irrelevant factors and an overly narrow interpretation of the statute governing attorney fees in mechanic’s lien cases.The South Dakota Supreme Court reversed the circuit court’s denial of attorney fees and remanded for a determination of an appropriate award of attorney fees consistent with its opinion. The court also awarded Smith Masonry $30,000 for appellate attorney fees. View "Smith Masonry v. Wipi Group Inc." on Justia Law