Justia South Dakota Supreme Court Opinion Summaries

In 2001, Plaintiff, a Honduran national, pleaded guilty to a felony in South Dakota and received a four-year suspended sentence. In 2013, Plaintiff filed a petition for a writ of error coram nobis seeking to vacate his 2001 conviction, asserting that the conviction was invalid because he pleaded guilty without being given Padilla and Boykin advisements. The circuit court granted the State’s motion for summary judgment. The Supreme Court affirmed, holding that because coram nobis was unavailable to remedy Plaintiff’s claimed Padilla and Boykin violations, the circuit court correctly granted summary judgment in favor of the State. View "Garcia v. State" on Justia Law

After a jury trial, Defendant was convicted of possessing and distributing synthetic marijuana. At trial, Defendant’s defense was that he mistakenly believed that the products had no illicit substances in them. On the question of knowledge, the State was required to prove Defendant’s awareness of the character and nature of the substances he was possessing and selling. On appeal, Defendant asserted that the trial court plainly erred when it gave the jury misleading and incomplete jury instructions on what was required to prove “knowing possession” of a controlled substance. The Supreme Court affirmed, holding (1) the circuit court adequately instructed the jury on the element of knowledge in the absence of a request for a more precise definition; and (2) the circuit court did not plainly err by not giving a mistake of fact instruction sua sponte. View "State v. Toben" on Justia Law

Plaintiffs brought a breach of contract action against H&S Builders, Inc. and retained Defendants to defend them in the lawsuit. Plaintiffs fired Defendants during the proceedings and hired a new attorney to assist them. The case was eventually settled. Plaintiffs then commenced this legal malpractice case against Defendants, claiming that Defendant failed properly to represent their interests in the action brought against H&S. The circuit court entered a default judgment as to liability in favor of Plaintiffs but concluded that Plaintiffs failed to prove they suffered any damages that were proximately caused by Defendants’ negligent representation. The Supreme Court affirmed, holding that the circuit court did not clearly err in finding that Plaintiffs failed to prove damages sustained as a proximately result of Defendants’ conduct. View "Peterson v. Issenhuth" on Justia Law

Defendant pleaded guilty to several offenses, including first-degree felony murder. Defendant was sentenced to death on the murder charge. The Supreme Court affirmed Defendant’s conviction and sentence. Defendant subsequently filed an application for writ of habeas corpus, claiming that he did not validly waive his right to have a jury determine whether to impose the death penalty. The Supreme Court granted the writ and vacated Defendant’s death sentence. On remand, Defendant filed a motion to withdraw his guilty pleas. The circuit court denied the motion on the merits, and the case proceeded to a jury sentencing. Thereafter, the jury sentenced Defendant to death. The Supreme Court affirmed the denial of Defendant’s motion to withdraw his guilty pleas and the proportionality of his sentence, holding (1) although the circuit court’s denial on the merits of Defendant’s motion to withdraw his guilty pleas was in excess of what was permitted by the limited remand, Defendant’s motion to withdraw his guilty pleas was properly denied; and (2) Defendant’s sentence was lawfully imposed by the jury. View "State v. Piper" on Justia Law

In the first appeal of this medical malpractice suit, the Supreme Court reversed and remanded a judgment for defendant Dr. Linda Peterson, holding that the trial court abused its discretion when it misconstrued the rules of evidence on the relevancy and admissibility of plaintiff Lita St. John's proffered evidence. On remand, defendant asked for reconsideration of the evidentiary rulings and reinstatement of the judgment. Concluding that the Supreme Court's opinion still left open the question whether the evidence was admissible, and ruling that it was not, the trial court declined to grant plaintiff a new trial and reinstated the judgment for defendant. Upon re-review, the Supreme Court reversed and remanded. "Many issues addressed by motions in limine, including evidentiary issues, are frequently reexamined during trial and the trial court may change rulings based on the actual evidence at trial. Thus, it was an error for the trial court in this case to reinstate a judgment based on reconsidering and ruling on a motion in limine outside of the context of a trial. We reverse the trial court's decision and remand for a new trial." View "St. John v. Peterson" on Justia Law

Magellan Pipeline Company, LP appealed a sales tax assessment levied by the state Department of Revenue and Regulation on its additive injection and equipment calibration services. The Hearing Examiner, Department Secretary and trial court all found Magellan's services were non-exempt from tax. Upon review, the Supreme Court concluded that under the plain language of the applicable statute, Magellan's services were exempt from sales tax. View "Magellan Pipeline Co v. Dept. of Revenue & Regulation" on Justia Law

Claimant worked for more than ten years as a diesel mechanic for Employer. Claimant had several incidents while working for Employer which he claimed caused neck, back, shoulder, and arm pain. Claimant later submitted a workers' compensation claim and three first reports of injury. Claimant then petitioned the Department of Labor, which denied Claimant workers' compensation benefits based on its finding that Claimant failed to prove by a preponderance of the evidence that his employment was a major contributing cause of his current condition and need for treatment. The circuit court affirmed but slightly modified the Department's decision. The Supreme Court reversed, holding that Claimant established by a preponderance of the evidence that his employment was a major contributing cause of his current condition and need for treatment. Remanded. View "Smith v. Stan Houston Equip. Co." on Justia Law

The Finnemans owned 17,000 acres of farmland that they deeded to Rock Creek Farms (RCF). RCF funded a series of redemptions of the property, and the Arnoldys purchased existing judgments on the property. Rabo Agrifinance and Rabo AgServices (Rabo) subsequently initiated foreclosure proceedings against the Finnemans, RCF, and all parties who had an interest in the land. The trial court entered a judgment and decree of foreclosure in the Rabo foreclosure proceedings and adjudged RCF as having the final owner's right of redemption as to the entirety of the property. The Arnoldys sought to have the judgment and decree of foreclosure set aside by filing a motion for relief pursuant to S.D. Codified Laws 15-6-60(b). On May 26, the trial court granted the motion and vacated the portion of the judgment recognizing RCF's final redemption rights. RCF and the Finnemans sought relief from the May 26 order by filing separate motions pursuant to Rule 60(b). The trial court denied relief. The Supreme Court affirmed, holding that the circuit court judge correctly determined that a Rule 60(b) motion was not appropriate and denied relief in this case. View "Rabo Agrifinance, Inc. v. Rock Creek Farms" on Justia Law

Thomas Konrad accepted a loan from Bob Law upon the advice of attorney Douglas Kettering. Law and Kettering had been partners in at least one of Law's business ventures and had an attorney-client relationship. Thomas's parents (the Konrads) provided their land as collateral for Thomas's loan. Thomas later defaulted on the note. Seven months after Kettering passed away, Law brought suit to enforce the note and mortgage against Thomas and the Konrads. Law settled with Thomas and the Konrads. Law then sought to recover from the Kettering Estate the amounts outstanding on the note, claiming that Kettering's acts - including his conflict of interest with Law and his alleged fraudulent inducement of the Konrads into signing the note and mortgage - voided the note and mortgage, and therefore, the Estate was liable to Law for the interest due on the note. The circuit court granted summary judgment for the Estate. The Supreme Court affirmed, holding (1) the contract between Law and Thomas did not contravene public policy because it was drafted by an attorney who failed to disclose a conflicting attorney-client relationship; and (2) the theory that Kettering fraudulently induced the Konrads into signing the note and mortgage rested on mere speculation. View "Law Capital, Inc. v. Kettering" on Justia Law

Hutterville Colony, a nonprofit religious corporation, had two opposing factions. Both factions sought exclusive power over Hutterville. Their schism led to two lawsuits, including one faction's suit seeking judicial dissolution of Hutterville. Eventually, the Supreme Court ordered dismissal of the suit, concluding that the circuit court lacked subject matter jurisdiction to order judicial dissolution of Hutterville. This appeal concerned the circuit court's actions following the Court's decision. The Supreme Court affirmed, holding (1) the circuit court did not err when it continued to exercise jurisdiction over Hutterville and its property following remittitur; (2) the circuit court had the authority and duty to wind up the receivership and discharge the receiver; (3) the circuit court did not abuse its discretion in ordering payment of the receiver's fees and expenses from receivership funds and allowing the receiver to use receivership funds to pay the expenses of third parties; (4) the circuit court did err in releasing the receiver from liability, as the receiver's appointment and receivership were valid under state law; and (5) the circuit court did not err in ordering the receiver to return receivership funds to the corporation. View "Wipf v. Hutterville Hutterian Brethren" on Justia Law