Justia South Dakota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of aggravated assault. Defendant appealed, alleging multiple errors in his trial. The Supreme Court (1) remanded for further proceedings on a potential Batson violation for the trial court's grant of a preemptory strike of a Native American juror, holding that Defendant established a prima facie case for purposeful discrimination in the preemptory strike, and because the circuit court failed to determine if Defendant proved that the State was motivated by purposeful discrimination, a limited remand was required to allow the circuit court to engage in the missing analysis; and (2) otherwise affirmed. View "State v. Scott" on Justia Law

Upon Marcus Degen's purchase of a home, Marcus purchased a homeowner's insurance policy with Hanson Farm Mutual Insurance Company of South Dakota (HFMIC). Marcus, Tina Sellers, and Tina's two daughters moved into the house. One evening, while Marcus was leveling dirt on the property with a skid loader, Marcus hit and killed one of the girls, Adrianna. Tina pursued a wrongful death action against Marcus a year later. HFMIC filed a declaratory judgment action asking the trial court to determine whether it had an obligation to indemnify or defend Marcus in the underlying wrongful death action. The trial court ruled in favor of HFMIC, determining that Adrianna was in Marcus's care and was therefore excluded from coverage under a household exclusion contained in the policy. Both Tina, as the personal representative of her daughter's estate, and Marcus appealed. The Supreme Court affirmed, holding (1) the trial court correctly concluded that the phrase "in your care" was unambiguous and in concluding that Adrianna was in Marcus's care; and (2) because she was in Marcus's care, Adrianna was excluded from coverage under the household exclusion contained in the policy. View "Hanson Farm Mut. Ins. Co. of S.D. v. Degen" on Justia Law

Claimant was employed full-time by School District (District). The District later notified Claimant it was replacing her full-time position with a part-time position, which would consist of seventy-five percent of the time of Claimant's full-time position and a twenty-five percent reduction in pay. Claimant rejected the offer of the part-time position and filed a claim for unemployment benefits. The Department of Labor and Regulation, Unemployment Insurance Division concluded that Claimant was eligible to receive unemployment benefits, and an ALJ affirmed. The Secretary of the Department of Labor reversed, finding that Claimant was not eligible to receive unemployment benefits. The circuit reversed, concluding that the part-time position was not "suitable" employment and that Claimant had good cause to reject the offer. The Supreme Court affirmed, holding that Claimant was eligible for unemployment benefits because the twenty-five percent pay reduction made the part-time position unsuitable and gave Claimant good cause to reject the new position. View "Easton v. Hanson Sch. Dist. 30-1 " on Justia Law

After a jury trial, Defendant was convicted of first-degree manslaughter by means of a dangerous weapon, vehicular homicide, vehicular battery, and DUI. Defendant was acquitted of two charges of first-degree manslaughter while engaged in the commission of a felony. Defendant appealed, arguing (1) the language "while engaged in the commission of a felony" was prejudicial when referring to the charge of DUI; and (2) the trial court improperly overruled her objections to the admissibility of testimony regarding the kinetic energy of Defendant's vehicle. The Supreme Court reversed and remanded for a new trial, holding (1) because the jury did not convict Defendant on the counts containing the language "while engaged in the commission of a felony," Defendant's argument that she was prejudiced was moot; but (2) the trial court erred when it concluded that the disputed testimony was relevant, and the error was not harmless. View "State v. Kvasnicka " on Justia Law

After a jury trial, Defendant was convicted of possession of one to ten pounds of marijuana. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion for judgment of acquittal, as the evidence was sufficient to sustain the conviction; (2) Defendant's proposed jury instructions were properly denied, as the instructions provided to the jury correctly stated the law and informed the jury; (3) the trial court did not abuse its discretion in denying Defendant's motion to have the jury view his residence; and (4) the trial judge did not abuse his discretion when he did not recuse himself on the basis of impartiality where Defendant provided no objective grounds to conclude the trial judge's impartiality might be reasonably questioned. View "State v. Hauge" on Justia Law

Mother and Father divorced in 1997. As part of their divorce, Mother and Father entered into an agreement regarding payment of their children's post-high school educational expenses. The parties' youngest child, Jason, took five years to complete his undergraduate degree and was accepted into several master's degree programs. At the end of Jason's senior year of college, Father began to dispute his obligation to continue paying his share of Jason's educational expenses. The circuit court found that the parties' agreement was unambiguous and ordered Husband to pay his share of the expenses associated with Jason's fifth year of undergraduate studies and Jason's first year of graduate school. The Supreme Court affirmed, holding (1) the agreement was intended to include graduate school and was not limited to an undergraduate education; and (2) Father was obligated to pay his pro-rata share of Jason's fifth year of college. View "Roseth v. Roseth" on Justia Law

Mother and Father, who were unmarried, had a child in 2002. In 2008, Father was awarded primary physical custody of the child. In 2012, Father petitioned to increase Mother's child support obligation because he lost his job and was unemployed. After a hearing, the referee recommended that Mother's obligation be reduced because Father had received part of an inheritance and expected to receive the balance of that inheritance in the near future. The circuit court adopted the referee's recommendation and reduced Mother's child support obligation. The Supreme Court reversed, holding that Father's inheritance could not be considered when calculating Mother's child support obligation without a finding that the child's needs were not being met through Father's and Mother's income. Remanded. View "Crawford v. Schulte" on Justia Law

Wife and Husband were married in 1997. Wife, who was diagnosed with relapsing-remitting multiple sclerosis, was declared disabled in 2002. In 2011, Husband initiated divorce proceedings. Husband's attorney (Attorney) prepared the marital termination agreement and affidavits. After a meeting with Attorney, Wife signed the agreement, which gave Husband the marital home, two vehicles, a utility trailer, Husband's retirement accounts, stocks, bonds, checking and saving accounts, and life insurance. Wife received approximately eight percent of the property, and she waived alimony. The judgment and decree of divorce were filed in September 2011. Wife subsequently filed a motion to set aside the judgment, which the trial court denied. The Supreme Court reversed and remanded for a trial on the merits, holding that Wife demonstrated exceptional circumstances constituting excusable neglect and a probable meritorious defense. View "Geier v. Geier" on Justia Law

Defendant was retried on multiple rape and sexual contact offenses against his daughter after his 2008 conviction was overturned on direct appeal. After a second jury trial, Defendant was convicted on all charges and was sentenced by the trial court to sixty years in the penitentiary. The Supreme Court affirmed, holding that the trial court did not abuse its discretion by (1) admitting evidence pertaining to Defendant's subornation of perjury conviction, as evidence of Defendant's act of fabricating evidence was relevant to Defendant's consciousness of guilt, and any prejudicial effect was substantially outweighed by the probative value of the evidence; and (2) denying Defendant's motion to dismiss based on a defective indictment, where the indictment was not fatally defective because it was neither duplicitous nor failed to apprise Defendant of the charges against him. View "State v. Fisher" on Justia Law

Appellant worked for the City of Sioux Falls as an assistant city attorney. In 2010, Appellant was terminated for violating various subsections of the Sioux Falls City Ordinance. Appellant appealed and applied for an alternative writ of mandamus to compel discovery of certain documents including personnel records of other city employees. The trial court denied the writ, determining that the files were not relevant to Appellant's appeal of his termination. The Supreme Court affirmed, holding (1) the trial judge had jurisdiction to preside over the writ of mandamus; (2) the trial court did not abuse its discretion in denying the writ of mandamus, as Appellant did not prove the existence of a clear legal duty to act; and (3) the trial court did not abuse its discretion in denying Appellant's motion for a new trial. View "Tornow v. Sioux Falls Civil Serv. Bd." on Justia Law