Justia South Dakota Supreme Court Opinion Summaries

The day after Julie served her husband Steven with a summons and complaint for divorce, Steven shot and killed Julie near her car in Julie's employer's parking lot. The personal representative of Julie's estate sought worker's compensation benefits for her death, asserting that Julie's death arose out of her employment. Julie's employer (Employer) denied benefits, as did the South Dakota Department of Labor and Regulation. The circuit court affirmed. The Supreme Court also affirmed, holding that even though the assault occurred on Employer's premises, the assault could not be attributed to Julie's employment, and therefore, Julie's death did not "arise out of" her employment. View "Voeller v. HSBC Card Servs., Inc." on Justia Law

After a jury trial, Defendant was convicted of manslaughter in the first degree. The Supreme Court affirmed, holding that the trial court (1) did not abuse its discretion in denying Defendant's motion to suppress and in admitting a video of Defendant's first interrogation, as Defendant made a knowing, voluntary, and intelligent waiver of her Miranda rights in the first interrogation; (2) did not err in refusing to instruct the jury on the lesser offense of manslaughter in the second degree; and (3) did not err in denying a jury instruction on burglary and allowing Defendant's counsel to appropriately argue the elements of justifiable homicide. View "State v. Waloke" on Justia Law

Defendant was indicted for murder in the second degree and aggravated assault after stabbing two men during an altercation. Defendant moved to suppress statements he made during a custodial interrogation, arguing that he had not validly waived his Miranda rights and that his statements were not voluntary. The circuit court denied the motion. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that Defendant's statements were obtained pursuant to a valid Miranda waiver and that the statements were voluntarily made; and (2) there was sufficient evidence to support the jury's rejection of Defendant's claim of self-defense. View "State v. Strozier" on Justia Law

After a jury trial, Defendant was convicted of driving under the influence of alcohol and for an open container violation. Defendant appealed, arguing that the trial court incorrectly denied his motion to suppress evidence obtained after the stop of his vehicle because the law enforcement officer had no reasonable suspicion of a violation of law to support the stop. The Supreme Court affirmed the conviction, holding that the circuit court did not err in denying Defendant's motion to suppress because the officer had a reasonable suspicion that Defendant's crossing of the fog line violated a statute requiring Defendant's vehicle to be "driven as nearly as practicable entirely within a single lane." View "State v. Hett" on Justia Law

Defendant, who was born in Mexico but moved to the United States before he was one year old, pleaded guilty to possession of marijuana. The United States later commenced removal proceedings against Defendant and Defendant was deported. Defendant later re-entered the United States. Defendant filed a motion to re-open and vacate his conviction for felony possession of marijuana, arguing that his counsel was deficient and that he would not have pleaded guilty if his counsel had advised him of the potential deportation consequences. The trial court denied the motion. The Supreme Court affirmed, holding that the U.S. Supreme Court's decision in Padilla v. Kentucky does not apply retroactively to a conviction that was final at the time Padilla was decided, including Defendant's conviction. View "State v. Garcia" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree rape and two counts of sexual contact with a child under age sixteen. Defendant was sentenced to fifty years incarceration for each of the first-degree rape convictions and fifteen years for each of the sexual contact convictions, with the sentences to run concurrently. Defendant appealed, arguing, among other things, that the indictment was duplicitous, and therefore, his right to jury unanimity was violated. The Supreme Court affirmed, holding (1) the trial court did not commit plain error in failing to strictly comply with the "either or rule" by either requiring the State to specifically elect the acts it would rely on at trial or by giving a unanimity instruction because the jury was ultimately informed of the unanimity requirement; (2) sufficient evidence supported both of Defendant's sexual contact convictions, but the evidence presented at trial was only sufficient to support one of Defendant's first-degree rape convictions; and (3) the sentences imposed by the trial court did not violate Defendant's Eighth Amendment right against cruel and unusual punishment. View "State v. Brende" on Justia Law

Mother and Father had Child out of wedlock. Following their separation, Mother retained primary physical custody of Child. Father later filed a motion for change of custody. The trial court determined that it was in Child's best interests that Father have primary physical custody of Child. Mother appealed. The Supreme Court affirmed, holding (1) based on its "balanced and thorough analysis" of the applicable factors provided in Fuerstenberg v. Fuerstenberg, the trial court did not abuse its discretion in determining that it was in the best interests of Child for Father to have primary physical custody; and (2) the parties' individual motions for appellate attorney fees were denied. View "Roth v. Haag" on Justia Law

Plaintiff, a property owner, sought to expand the buildings on his property and, accordingly, asked the City to rezone a portion of his property zoned within the Flood Hazard Zoning District. The City denied the request along with Plaintiff's building permits because the proposed expansion extended to a portion of Plaintiff's property zoned within the Flood Hazard Zoning District. After unsuccessfully appealing to the Zoning Board of Adjustment, Plaintiff filed a complaint with the circuit court, which included a writ of certiorari, a request for declaratory judgment, a writ of mandamus, a civil rights claim, and a state constitutional claim. While the suit was pending, the City partially granted Plaintiff's rezone request. The circuit court subsequently denied Plaintiff's writ of certiorari and granted summary judgment in favor of the City on the remainder of Plaintiff's claims. The Supreme Court affirmed, holding that the circuit court did not err in dismissing Plaintiff's writ of certiorari and granting summary judgment in favor of the City on Plaintiff's remaining claims. View "Parris v. City of Rapid City" on Justia Law

JAS Enterprises, Inc. (JAS) entered into a purchase agreement with BBS Enterprises, Inc. (BBS), which sold vehicles, equipment, and inventory used in a sheet metal installation business. The agreement also contained a covenant not to compete. The agreement was signed by the Statons as personal guarantors of the agreement. When BBS failed to make timely monthly payments, JAS filed suit against BBS and the Statons, alleging breach of contract. BBS and the Statons counterclaimed, arguing that JAS and James Swaby, JAS's principal shareholder, violated the covenant not to compete. A jury concluded that BBS and the Statons breached their contract and that JAS and Swaby breached the covenant not to compete. The Supreme Court reversed in part, holding that the trial court (1) erred when it denied Swaby's motion to dismiss him personally; (2) erred in admitting certain testimony; (3) erred in admitting parol evidence in interpreting the contract; and (4) erred by not requiring the jury to choose the date when the damage occurred to enable the trial court to properly calculate prejudgment interest. Remanded. View "JAS Enters., Inc. v. BBS Enters., Inc." on Justia Law

The mother of three girls (Mother) signed a petition to voluntarily terminate her parental rights, attesting in an affidavit that she believed it to be in the best interests of her children for her children to remain with their father and to be adopted by his wife. After a termination hearing, the circuit court found Mother had voluntarily consented to the termination of her parental rights and ordered permanent termination. The court then entered judgment declaring the children to be the adopted children of their stepmother. Mother later moved to vacate the judgment terminating her parental rights, alleging fraud upon the court because she was "secretly paid" monetary consideration and given "secret promises" of continued visitation with her children. The court denied Mother's motion to vacate, ruling that Mother failed to establish exceptional circumstances warranting relief. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in balancing undisclosed side agreements and unsettled arrangements for continued parent contact with the children's need for stability and finality. View "In re Termination of Parental Rights of Ibanez" on Justia Law