Justia South Dakota Supreme Court Opinion Summaries

Defendant was charged with possession of cocaine, possession of marijuana, and ingestion of marijuana. Defendant moved to suppress the evidence as the fruit of an illegal search of his hotel room. The trial court granted the motion with respect to the drugs seized during the initial illegal search but denied the motion with respect to evidence gathered during a subsequent call to the hotel. After a trial, Defendant was convicted as charged. The Supreme Court affirmed, holding the trial court did not err in denying in part Defendant's motion to suppress evidence, as the second call to police constituted an independent source of evidence against Defendant and that the evidence obtained thereby bore no causal connection to the evidence illegally seized in Defendant's hotel room. View "State v. Heney" on Justia Law

Appellant was injured in 2008 while working for Employer. In 2010, Appellant received an injury she believed was a "flare-up" from the earlier injury. Appellant subsequently petitioned the Department of Labor for benefits. Because Appellant's original petition did not assert that the 2010 incident caused a recurrence of her 2008 injury, Appellant amended her petition making that assertion. Employer argued that Appellant's claim was time barred under her amended petition. Appellant respondent that the claims in her amended petition related back to her original petition, which was filed before the expiration of the statute of limitations. The administrative law judge (ALJ) ruled that Appellant's claims in her amended petition did not relate back to her original petition and granted summary judgment to Employer. The Supreme Court reversed and remanded with direction that the ALJ allow Appellant's amended petition to relate back to the date of her original petition, holding that to not allow Appellant to proceed on a claim that all parties agreed was a recurrence of her 2008 compensable work-related injury because Appellant failed to posture her request for relief in her original petition as a recurrence contravened the spirit of the state's worker's compensation laws.View "Waterman v. Morningside Manor" on Justia Law

Border States Paving Company, Inc. was the prime contractor on a South Dakota Department of Transportation road construction project. Weatherton Contracting Company, Inc. entered into a subcontract with Border States to supply crushed aggregate for the project. Stern Oil Company sold Weatherton fuel and petroleum products necessary for Weatherton to perform its subcontract, but Weatherton failed to pay Stern Oil for the products. Stern Oil Company brought suit against Border States and its surety, Liberty Mutual Insurance Company, pleading causes of action against Border States for unjust enrichment and breach of an alleged third-party beneficiary payment agreement to pay the bill and against Liberty Mutual for payment on the bond. The circuit court granted summary judgment against Stern Oil on all claims. The Supreme court affirmed, holding that the circuit court did not err in granting summary judgment against Stern Oil on its claims. View "Stern Oil Co. v. Border States Paving, Inc." on Justia Law

After a jury trial, Defendant was convicted of aggravated assault, discharge of a firearm at a car, and possession of a firearm by a prohibited person. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion when it admitted evidence of Defendant’s 2002 conviction as other act evidence under S.D. R. Crim. P. 404(b), where the probative value of the evidence outweighed the potential for unfair prejudice; and (2) the State presented sufficient evidence to support the jury’s verdict finding Defendant guilty of aggravated assault. View "State v. Boe" on Justia Law

After Plaintiff obtained a judgment against Logs Unlimited, Inc., the corporation transferred its assets to Thomas Schramel, Schramel's daughter, and another corporation. Schramel was the sole shareholder, director, and officer of both corporations. Proceeds from the transfer were used to pay some of Logs Unlimited's creditors, but Plaintiff was not among the creditors paid. Plaintiffs sued Logs Unlimited, claiming that it had fraudulently transferred its assets. The circuit court set aside the transfer, concluding that Logs Unlimited fraudulently transferred its assets to prevent satisfaction of Plaintiff's judgment. The Supreme Court affirmed, holding that, upon consideration of the relevant factors, the transfer was fraudulent under S.D. Codified Laws 54-8A-4(a)(1).View "Nielsen v. Logs Unlimited, Inc." on Justia Law

Defendant, who was fifteen years old and a native Spanish speaker, was transported to the police department for questioning in connection with the death of Jasmine Guevara. During her questioning by police, Defendant confessed to the murder. Defendant moved to suppress her confession, arguing that she did not voluntarily, knowingly, and intelligently waive her Miranda rights. The juvenile court denied the motion. The case was then transferred to adult court in the First Judicial Circuit. The trial court reopened the motion to suppress and granted the motion, concluding that Defendant made her statements voluntarily but did not knowingly and intelligently waive her rights. The State appealed. The Supreme Court reversed, holding that the trial court erred in suppressing Defendant’s confession where the State met its burden to show more likely than not that Defendant’s waiver of her Miranda rights was “with a full awareness of both the nature of the right being abandoned and the consequences of the decision to abandon it.” View "State v. Diaz" on Justia Law

The South Dakota Department of Revenue and Regulation (Department) issued Appellant a jeopardy assessment alleging unpaid sales tax. On appeal, a hearing examiner found Appellant liable for a jeopardy assessment, and the Secretary of Revenue adopted the decision. The circuit court dismissed Appellant's appeal, holding that Appellant's failure to pay the amounts affirmed by the Secretary or to file a bond before commencing its appeal resulted in the failure to preserve jurisdiction in the court. The Supreme Court affirmed, holding (1) Appellant's failure to post its bond within the statutory period was fatal to its appeal; (2) Appellant failed to substantially comply with the relevant statute; and (3) the time for Appellant to post its bond could not be equitably tolled.View "AEG Processing Ctr. No. 58, Inc. v. S.D. Dep't of Revenue & Regulation" on Justia Law

After a jury trial, Defendant was convicted of first-degree kidnapping, second-degree rape, and aggravated assault. The Supreme Court affirmed Defendant's convictions. Defendant subsequently filed an amended application for writ of habeas corpus, alleging that he was denied effective assistance of counsel, a fair trial, and due process of law. The habeas court denied the writ. The Supreme Court affirmed, holding (1) the habeas court correctly determined that Defendant failed to demonstrate ineffective assistance of counsel; (2) Defendant's due process claim regarding cross-examination of the victim concerning her sexual activity before the rape and her post-rape drug charge were res judicata; and (3) the habeas court correctly determined that Defendant's remaining due process argument lacked evidentiary support.View "Fast Horse v. Weber" on Justia Law

Amanda Pfuhl obtained a temporary protection order against her husband Jason. One month later, the circuit court continued the protection order for another month and appointed counsel, Tressa Kool, for the couple’s minor children. After the matter was heard again, the protection order was dismissed for failure to provide sufficient evidence. Kool subsequently sought costs related to her appointment. The circuit court ordered that Minnehaha County (“Minnehaha”) pay Kool $1094. Minnehaha appealed. On appeal, the circuit court argued that S.D. Codified Laws 26-8A-18 required the appointment counsel for the minor children and required ordering Minnehaha to pay appointed counsel’s costs. The Supreme Court reversed, holding that the circuit court lacked statutory authority in this case to order Minnehaha to pay appointed counsel’s costs because section 26-8A-18 applies to the particular subject of a child’s status or condition, and that was not the particular subject of the proceeding the circuit court presided over. View "Pfuhl v. Pfuhl" on Justia Law

After Earl Long died, Earl’s daughter, Brenda Chafin, challenged the validity of Earl’s estate plan, which included certain gifts and amendments to his trust. The circuit court concluded that Earl’s estate plan was valid. The Supreme Court affirmed, holding (1) the circuit court did not err when it determined that Earl had the requisite testamentary capacity to carry out his estate plan; (2) the circuit court was correct in determining that Earl’s estate plan was not the product of undue influence; and (3) the circuit court did not err by not requiring the distributions to be equalized under a review of Earl’s entire estate plan. View "In re Estate of Long" on Justia Law