Justia South Dakota Supreme Court Opinion Summaries

Michael Manuel, the sole owner of Toner Plus, Inc., closed his business on May 30, 2009. Manuel then filed a personal claim for unemployment compensation benefits. The South Dakota Department of Labor determined that Manuel was ineligible to receive unemployment compensation benefits because he "voluntarily" dissolved his business and did not have "good cause" for doing so under S.D. Codified Laws 61-6-13 to -13.1 The circuit court affirmed. The Supreme Court affirmed, holding (1) the ALJ did not err in finding the Department met its burden of showing Manuel's decision to terminate his employment with Toner Plus was voluntary; and (2) the Court did not need to address whether Manuel had "good cause" for voluntarily terminating his employment. View "Manuel v. Toner Plus, Inc." on Justia Law

Mother and Father, who were never married, had one child, N.B. After Mother and Father ended their relationship, Mother retained custody of N.B. Mother subsequently entered into another romantic relationship, which produced N.B.'s half-sister, A.K. Later, Father filed an action requesting the trial court to grant him custody of N.B. The trial court granted Father's request, reasoning that Father would provide N.B. with heightened stability. Mother appealed, arguing that the trial court abused its discretion in concluding that compelling circumstances warranted the separation of siblings. The Supreme Court affirmed, holding (1) the trial court properly considered the relevant factors in making its custody determination, and its finding that compelling reasons existed to separate N.B. from her half-sibling was not clearly erroneous; and (2) therefore, the court did not abuse its discretion in awarding primary physical custody to Father. View "Beaulieu v. Birdsbill" on Justia Law

Jeannine and Donald Barton divorced, and the circuit court awarded Jeannine permanent alimony, a monetary judgment, and attorney fees. After Donald filed for bankruptcy, the court issued an order clarifying the nature of the monetary judgment. Jeannine and Donald later entered into a settlement agreement regarding the judgment. The agreement, which was not incorporated into the divorce decree, resolved a dispute regarding the judgment and released all present and future claims between the parties. Nine years later, Jeannine moved to modify alimony. The circuit court granted the motion after noting that Donald's financial situation had changed and (1) increased Jeannine's monthly alimony award, and (2) extended Donald's alimony obligation beyond Donald's death. The Supreme Court reversed, holding that the circuit court's findings when it considered modification did not support a change in circumstances justifying a modification of alimony, as the original divorce decree was not predicated solely on Donald's ability to pay but also took into account Jeannine's need. View "Barton v. Barton" on Justia Law

Dennis Most was convicted in a bench trial of four counts of sexual contact with a child. Most appealed, contending (1) the trial court erred in denying his motion to exclude prior acts evidence and his motion to offer the victim's prior allegation of sexual assault, and (2) there was insufficient evidence to sustain his convictions. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion when it admitted prior acts evidence; (2) the trial court did not abuse its discretion when it denied Most's motion to offer evidence of the victim's prior allegation of sexual assault; and (3) there was sufficient evidence to sustain Most's convictions. View "State v. Most" on Justia Law

John Graham, a Canadian citizen, was convicted of felony murder and sentenced to life imprisonment without parole. Graham appealed, raising a number of arguments, including the contention that because he was extradited from Canada on a federal premeditated murder charge, under the specialty doctrine of federal extradition law, the State lacked personal jurisdiction to prosecute him on the State felony murder charge. The Supreme Court affirmed, holding (1) because Canada consented to waive specialty with respect to the state charge at issue, the State had jurisdiction to prosecute Graham for felony murder; (2) the circuit court erred in admitting certain hearsay, but the error was harmless; (3) there was sufficient evidence to sustain a finding of guilt beyond a reasonable doubt; and (4) Graham's life sentence without parole was authorized by statute and was constitutional under the Eighth Amendment. View "State v. Graham" on Justia Law

Sometime after he lit his pilot light, Darrick Van Dyke's home burned down from a propane explosion. The fire spread, destroying Marguerite Cashman's home next door. Cashman brought suit against Van Dyke, alleging negligence, strict liability, and res ipsa loquitur. The circuit court granted summary judgment for Van Dyke, ruling that Cashman failed to present any evidence that Van Dyke acted negligently, that lighting a pilot light was an abnormally dangerous activity, or that the doctrine of res ipsa loquitur applied. The Supreme Court affirmed, holding that the circuit court did not err in granting summary judgment to Van Dyke. View "Cashman v. Van Dyke" on Justia Law

Anthony Webb appealed an order reducing child support arrearages to a written judgment in favor of his ex-wife, Kathy Webb. The circuit court awarded Kathy a judgment of $71,805. Anthony appealed, arguing that he paid the child support as it came due and that the passage of time should prevent Kathy from recovering. The Supreme Court affirmed, holding (1) because Anthony presented no testimony at trial, the uncontroverted evidence before the circuit court established the existence and amount of the unpaid child support obligation; and (2) the circuit court did not err by refusing to apply the doctrine of judicial estoppel or laches to Kathy's claim, nor did it abuse its discretion in denying Anthony's motion for new trial. View "Webb v. Webb" on Justia Law

Kyle Steiner pleaded guilty to one count of sexual contact with a child and was sentenced to fifteen years in prison. Steiner subsequently filed an application for a writ of habeas corpus, claiming that his trial counsel was ineffective. Without conducting an evidentiary hearing, the circuit court dismissed the application. The Supreme Court reversed the judgment of the circuit court, holding that the circuit court was premature in dismissing Steiner's petition without conducting an evidentiary hearing on the merits, as Steiner alleged facts which, if proven to be true, would support a claim for relief, and Steiner's allegations were not unspecific, conclusory, or speculative. View "Steiner v. Weber" on Justia Law

This foreclosure action involved a dispute between two creditors, Wells Fargo Financial South Dakota, Inc. and Highmark Federal Credit Union about the priority of their respective mortgage liens against a property. Both parties asserted that they were entitled to first priority. The trial court found that, despite Highmark's statutory priority, under the doctrine of equitable subrogation, Wells Fargo was entitled to first priority. The Supreme Court reversed, holding (1) equity in this case did not require the trial court to pierce the South Dakota recording statutes; and (2) because Highmark filed its lien on the property prior to Wells Fargo, Highmark had priority. View "Highmark Fed. Credit Union v. Wells Fargo Fin. S.D., Inc." on Justia Law

Dan Prue sold his majority interest in DT-Trak Consulting, a medical coding business, for a lump-sum payment and several annual payments. DT-Trak withheld an annual payment, asserting that Prue had violated the parties' stock purchase agreement. The matter proceeded to arbitration. A three-member arbitration panel made an award in Prue's favor. DT-Trak sought to vacated the award, alleging that the arbitrator it selected demonstrated evident partiality and that the panel's findings of fact and conclusions of law were insufficient. The circuit court affirmed. The Supreme Court affirmed, holding that under either the Federal Arbitration Act or South Dakota Arbitration Act, DT-Trak failed to show that the arbitration award should be vacated, as (1) there was no support that any member of the arbitration panel exhibited evident partiality; and (2) the findings of fact and conclusions of law submitted by the panel were sufficient under the requirements of the agreement. View "DT-Trak Consulting, Inc. v. Prue" on Justia Law