Justia South Dakota Supreme Court Opinion Summaries

After witnessing Blair Hamilton accidentally kill himself in October 2009, Lyndon Hart in August 2011 filed a petition to extend time to file a creditor's claim against Hamilton's Estate for the negligent and intentional infliction of emotional distress caused by the actions of Hamilton. The circuit court denied the petition. Hart appealed and served his notice of appeal only on the Estate's attorney. The Supreme Court affirmed, holding (1) the Estate's motion to dismiss the appeal for failure to serve notice of appeal on all the heirs was denied, as in this case, the heirs were not parties in a creditor's claim against an estate; and (2) because Hart did not present or file a claim, the Court could not reach the merits of Hart's argument on appeal that the circuit court erred in denying his motion to extend time to file a creditor's claim. View "In re Estate of Hamilton" on Justia Law

This case involved a grandchildren visitation disagreement between a father and maternal grandparents. After the children's mother died, the father arranged for the children's continued contact with the grandparents. However, the grandparents were unhappy with the father's restrictions on visitation, and they filed a petition for a broader visitation plan. At the close of the grandparents' case-in-chief, the circuit court granted the father's motion for a judgment as a matter of law and motion for attorney's fees. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion (1) in granting the father's motion for a judgment as a matter of law, as the grandparents did not present any evidence rebutting the father's presumptive parental right to control the custody and visitation of his children; and (2) awarding attorney's fees, as the court's findings and conclusions were based on sufficient evidence and were sufficient to support the award. View "Beach v. Coisman" on Justia Law

Heidi Schumacher signed a renewed lease with Meadowland Apartments. Meadowland later filed an eviction action against Schumacher, alleging that she was in material non-compliance with the lease because Schumacher kept a disruptive dog in her apartment. The magistrate court found that Schumacher's conduct constituted sufficient grounds for termination of the lease. The circuit court affirmed. The Supreme Court affirmed, holding that the magistrate court (1) did not abuse its discretion in denying Schumacher's motion for a continuance, as Schumacher was given a reasonable opportunity to secure evidence on her behalf; (2) did not abuse its discretion in considering evidence of incidents that occurred prior to the term of Schumacher's most recent lease with Meadowland; and (3) did not err in finding that Meadowland provided reasonable accommodations for Schumacher's disability as required under the Fair Housing Amendments Act. View "Meadowland Apartments v. Schumacher" on Justia Law

Appellant Ryan Rademaker was arrested for driving while under the influence of alcohol. Rademaker moved to suppress all evidence obtained from the stop of his vehicle, arguing that the stop violated his Fourth Amendment right to be free from unreasonable search and seizures. The trial court denied his motion and convicted Rademaker of driving under the influence. Rademaker appealed. The Supreme Court affirmed the trial court's ruling on the issue, holding that, based on the totality of the circumstances, the law enforcement officer had reasonable suspicion to stop Rademaker's car, and thus, the stop did not violate Rademaker's Fourth Amendment rights. View "State v. Rademaker" on Justia Law

James Cornelius initiated a declaratory judgment action against National Casualty Company to determine whether a policy of insurance issued by National Casualty to Cornelius's employer, Live Line Maintenance, provided uninsured motorist coverage to Cornelius for injuries he sustained while occupying a vehicle owned by Live Line. The circuit court granted National Casualty's motion for summary judgment, finding that Cornelius could not recover uninsured motorist benefits. The Supreme Court reversed, holding that the circuit court erred in granting summary judgment for National Casualty because Cornelius presented evidence to support his claim that there was a casual connection between Live Line and Live Line's proprietor's alleged negligent maintenance of the work vehicle and the accident that caused Cornelius's injuries. View "Cornelius v. Nat'l Cas. Co." on Justia Law

Minority shareholders (Plaintiffs) brought this action against minority shareholders (Defendants), individually and as officers or directors of Multi-Community Cooperative Dairy (MCC Dairy). Plaintiffs' amended complaint alleged six causes of action, including oppression and/or unfairly prejudicial conduct toward minority shareholders, breach of fiduciary duty, tortious interference, and restraint of trade or commerce. The circuit court granted Defendants' motion for summary judgment on the amended complaint. The court also granted Defendants' motion for sanctions on the ground that Plaintiffs and their counsel had abused the discovery process. The Supreme Court affirmed, holding (1) the circuit court id not err as a matter of law in granting summary judgment, as there was no support that Defendants engaged in any wrongdoing; and (2) the circuit court did not abuse its discretion in ordering sanctions against Plaintiffs for abuse of discovery in refusing to attend depositions scheduled by Defendants. View "Veblen Dist. v. Multi-Cmty. Coop. Dairy" on Justia Law

Eric Robert was under a sentence of death entered by a circuit court judge and let the time to file an appeal expire. Nevertheless, the Supreme Court in this case was statutorily obligated to review his sentence. The Court subsequently stayed Robert's execution and established a briefing schedule. Robert filed a motion to vacate those orders, arguing that the obligation to review his sentence did not grant the Court additional jurisdiction to stay his execution or to enter a briefing schedule. The Supreme Court denied the motion to vacate, holding that Robert's interpretation of S.D. Codified Laws 23A-27A-21, which included the argument that because Robert had not filed a notice of appeal the stay of proceedings contemplated by the statute was not available, was incorrect, as it would lead to an absurd result, flew in the face of the Court's authority, and was inconsistent with the constitutional analysis of the U.S. Supreme Court. View "State v. Robert" on Justia Law

In a disciplinary proceeding, the South Dakota Real Estate Commission found that Cheri St. Pierre, a licensed broker associate, had engaged in unprofessional conduct involving dishonesty. The Commission suspended her license for one year, but held the suspension in abeyance on conditions, including the payment of a penalty and repayment of the Commission's attorney's fees. The circuit court reversed the Commission's conditional suspension. The Supreme Court reversed the circuit court and reinstated all terms of the Commission's conditional suspension except the provision requiring the repayment of the Commission's attorney's fees, holding (1) St. Pierre engaged in unprofessional conduct within the meaning of S.D. Codified Laws 36-21A-71(15); (2) the Commission was without authority to conditionally order St. Pierre to reimburse the Commission for its attorney's fees expenses as part of its discipline; and (3) the Commission had authority to order St. Pierre to pay a $1,000 penalty as a condition of avoiding a suspension. View "St. Pierre v. State ex rel. S.D. Real Estate Comm'n" on Justia Law

After a jury trial, Simon Torres was convicted of attempted murder and commission of a felony with a firearm. Torres appealed. The Supreme Court affirmed, holding that the trial court (1) did not abuse its discretion in denying Torres's motion in limine to exclude a cell phone video of the shooting and photographs of the victim's gunshot wounds, as Torres did not establish that the photographs were unfairly prejudicial or that the trial court incorrectly determined that the photographs' probative value outweighed this potential prejudice; and (2) did not violate Torres's due process rights during arraignment by failing to advise him that he would receive mandatory consecutive sentences if convicted of both attempted murder and commission of a felony with a firearm. View "State v. Torres" on Justia Law

Pooled Advocate Trust, Inc. (PATI), the managing corporation for a Medicaid pooled trust, brought a declaratory judgment action on Medicaid eligibility issues associated with the trust and named the South Dakota Department of Social Services (DSS) as a necessary party. The circuit court granted declaratory judgment for PATI. Fred and Gladys Matthews transferred assets to the pooled trust. When the Matthews subsequently applied for Medicaid long-term care benefits, DSS imposed a penalty period because they were over age sixty-five at the time of the transfers. PATI petitioned for further relief, seeking a declaration that DSS could not impose penalty periods for transfers made by pooled trust beneficiaries age sixty-five or older. The circuit court granted PATI's petition. The Matthews also appealed DSS's application of a penalty period, but an ALJ upheld the decision and another circuit court affirmed. DSS appealed the circuit court's order granting PATI's petition and the Matthews appealed the other circuit court's affirmance of the ALJ's ruling. The Supreme Court affirmed the administrative appeal and reversed the declaratory judgment, holding that transfers of assets into pooled trusts by beneficiaries age sixty-five or older may be subject to a transfer penalty period for Medicaid eligibility purposes. View "In re Pooled Advocate Trust" on Justia Law