Justia South Dakota Supreme Court Opinion Summaries

At issue in this appeal was a continuing dispute between Appellants, David and Connie Finneman and Rock Creek Farms Partnership (RCF), and Ann Arnoldy concerning the ownership of 16,700 acres of farmland. After a series of lawsuits, appeals, and various filings, the circuit court granted Arnoldy equitable ownership of the real estate outlined in two contracts for deed. The Supreme Court affirmed, holding, primarily, that the circuit court did not err in granting Arnoldy equitable ownership of the real estate in the contracts for deed and the right to cure the contracts for deed default under S.D. Codified Laws 21-50-3. View "L&L P’ship v. Rock Creek Farms" on Justia Law

Appellant submitted an application for a writ of mandamus asking the circuit court to compel Secretary of State Jason Gant to investigate the nominating petitions for Republic candidate Brian Gosh for the November 2012 election in Pennington County. The court dismissed Appellant’s application for failure to state a claim for which relief could be granted. Intervenors to the case moved to award attorney’s fees and to tax costs and disbursements against Appellant. Appellant, in the meantime, appealed the dismissal of her application. Subsequently, after a hearing, the circuit court granted the Intervenors’ motion. The Supreme Court affirmed the circuit court’s order, holding (1) the circuit court did not err in awarding the Intervenors attorney's fees after the hearing; (2) the court did not err when it held a hearing on the Intervenors’ motion for attorney’s fees and expenses while Appellant’s appeal on the underlying judgment on the merits was pending before the Court; and (3) Appellant was not entitled to relief on the Intervenors’ motion for attorney’s fees because Appellant failed to assert her issue with the circuit court when given the opportunity to do so. View "Strong v. Gant" on Justia Law

A federal court issued an arrest warrant for Christopher Yellow Eagle, whose warrant was referred to a task force that included federal and county law enforcement officers. The task force officers learned Yellow Eagle was living with Defendant, who had an outstanding warrant for her arrest. The task force arrested Defendant and Yellow Eagle at Defendant’s home after observing that Defendant and Yellow Eagle appeared to be under the influence of a controlled substance and had drugs on their persons. After a court trial, Defendant was convicted of possession of a controlled substance and sentenced to four years incarceration with four years suspended. Defendant appealed the circuit court’s denial of her motion to suppress, arguing (1) the task force officers who executed the arrest warrant were not authorized to enter her home to arrest her, and (2) because Yellow Eagle was a third party in her home, the officers were required to obtain a separate search warrant for the home. The Supreme Court affirmed, holding that the task force officers constitutionally entered Defendant’s home to arrest Defendant, or alternatively, Yellow Eagle. View "State v. Quevedo" on Justia Law

After a jury trial, Defendant was found guilty of eight counts of making false or fraudulent sales tax returns. On appeal, Defendant argued that the circuit court erred in (1) denying his Batson challenges to three peremptory strikes exercised by the State because the court’s Batson analysis was incomplete; and (2) denying his motion for judgment of acquittal. The Supreme Court (1) held that because the Court was unable to determine under the record the circuit court’s reason for denying the Batson challenges, limited remand was required to allow the circuit court to engage in the missing analysis; and (2) affirmed the denial of Defendant’s motion for judgment of acquittal, as the evidence was sufficient to sustain the convictions. View "State v. Guthmiller" on Justia Law

Plaintiff sued Defendant for specific performance of Plaintiff’s option to purchase a ranch owned by Defendant. Defendant counterclaimed, alleging that Plaintiff owed him rent. After a trial, the circuit court (1) denied Plaintiff’s request for specific performance, concluding that Plaintiff had not performed all the conditions precedent on his part; and (2) concluded that the parties had an implied or express contract requiring Plaintiff to pay Defendant rent. The Supreme Court (1) held that the circuit court did not clearly err in finding Plaintiff was the party who was materially at fault for the failure of the conditions and in therefore denying specific performance, but because the record did not reflect that the court considered whether specific performance was appropriate under the exception set forth in S.D. Codified Laws 21-9-5, the case was remanded for reconsideration of specific performance under this exception; and (2) the circuit court erred in concluding that either an express or an implied contract required Plaintiff to pay rent. View "Humble v. Wyant" on Justia Law

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