Justia South Dakota Supreme Court Opinion Summaries

Appellant Jason Larsen-Smith was convicted of manslaughter in the first degree and sentenced to life without parole. Appellant appealed, arguing that the sentence amounted to cruel and unusual punishment in violation of the Eighth Amendment. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in sentencing Appellant where (1) the sentence did not appear grossly disproportionate to the crime, (2) Appellant received a statutorily authorized sentence for his conviction, and (3) the circuit court properly acquired a thorough acquaintance with Appellant and imposed a sentence that took into consideration the safety of the public and Appellant's prospects for rehabilitation. View "State v. Larsen-Smith" on Justia Law

Employee received workers' compensation benefits for a neck and back injury he suffered in 2002 while working for Employer. After his benefits were discontinued in 2004, Employee sought treatment for a low back condition and petitioned the Department of Labor for workers' compensation benefits. The Department denied the petition, ruling that Employee did not prove his low back condition was related to his original 2002 work injury. The circuit court affirmed. The Supreme Court affirmed, holding that the Department correctly denied workers' compensation benefits where Employee failed to establish by a preponderance of the evidence that the 2002 injury was a major contributing cause of his current low back condition. View "McQuay v. Fischer Furniture" on Justia Law

Ethanuel Holznagel and John Cutsinger were involved in a car accident, and Holznagel died from injuries sustained in the accident. Holznagel's parents (Plaintiffs), the representatives of his estate, brought a wrongful death action against Cutsinger and his employer (Defendants). A jury trial was held and a verdict was returned for Defendants. Plaintiffs appealed the grant of Defendants' motion in limine excluding evidence of Cutsinger's marijuana use. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in determining that the probative value of the evidence was outweighed by the danger of unfair prejudice and granting Defendants' motion in limine. View "Estate of Holznagel v. Cutsinger" on Justia Law

Former students of a parochial school brought an action against the Congregation of the Priests of the Scared Heart, Inc. (PSHI) and other defendants, asserting claims of childhood sexual abuse. PSHI filed a motion to dismiss the action on the grounds that the former students failed to timely serve process on PSHI. The circuit court denied PSHI's motion to dismiss, finding (1) the former students substantially complied with the applicable service-of-process statute, and (2) service of process on PSHI was valid under S.D. Codified Laws 15-2-31. The Supreme Court affirmed, holding that the former students timely served PSHI in accordance with South Dakota law, and the circuit court did not err in denying PSHI's motion to dismiss. View "R.B.O. v. The Congregation of the Priests of the Sacred Heart, Inc." on Justia Law

Former students of a parochial school brought an action against the Priests of the Sacred Heart (PSH) and other defendants, asserting claims of childhood sexual abuse. PSH filed a motion to dismiss the action on the grounds that the former students failed to timely serve process on PSH. The circuit court denied the motion to dismiss, finding (1) the former students substantially complied with the applicable service-of-process statute, and (2) service of process on PSH was valid under S.D. Codified Laws 15-2-31. The Supreme Court reversed, holding that the circuit court erred in denying PSH's motion to dismiss because Plaintiffs failed to direct service to PSH and therefore failed to substantially comply with South Dakota's statutory notice requirements. View "R.B.O. v. Priests of the Sacred Heart" on Justia Law

Border States Paving was awarded the prime contract by the state DOT for a road project. Border States entered into a subcontract with Morris, Inc. for aggregates and work on the project. During work on the project, the DOT orally informed Morris that certain materials passed the soundness test. However, the materials actually failed. Ultimately, the paving was not completed by the seasonal deadline. When the project was completed the next year, the DOT paid Border States in full. Border States withheld several thousand dollars from Morris for costs associated with the project because it believed Morris defaulted in its contractual obligations under the subcontract. Morris brought suit against the DOT, alleging that the DOT breached its express and implied contractual obligations owed to Morris and that the DOT breached its implied contractual obligation of good faith and fair dealing. The circuit court ruled in favor of Morris and awarded Morris damages. The Supreme Court reversed, holding that there was insufficient evidence that the DOT's erroneous pass report proximately damaged Morris where there was no evidence in the record that this error alone caused the project to not get completed by the deadline. View "Morris, Inc. v. State ex rel. Dep't of Transp." on Justia Law

Plaintiff ranchers sued the State because of ongoing damage to their property from incursions of prairie dogs from public lands. Relying on multiple statutes requiring the State to manage and control prairie dog populations, Plaintiffs requested injunctive relief, abatement, and damages. The circuit court granted summary judgment in favor of Plaintiffs and ordered a trial on damages. When the case was reassigned, the State moved the new judge to reexamine the first judge's ruling. On reconsideration, the court vacated the first summary judgment and granted summary judgment for the State. The Supreme Court affirmed, holding that the second circuit court judge did not err in granting summary judgment for the State where the acts mandated by the statutes cited by Plaintiffs were discretionary and the State was protected from suit by sovereign immunity. View "Adrian v. Vonk" on Justia Law

Upon issuing a divorce decree, the trial court awarded Wife $500 per month in alimony for eight years and attorney's fees. In granting the alimony, the court considered Husband's social security and military disability payments but did not order attachment of those benefits. The Supreme Court affirmed, holding (1) given that Husband's social security disability benefits were subject to garnishment for alimony under federal law, the circuit court did not err in merely considering the benefits in determining whether an alimony award was appropriate; (2) the circuit court did not abuse its discretion in finding that Wife demonstrated a need for and Husband's ability to pay alimony; and (3) considering Wife's resources and income and the complex legal issues in this case requiring briefing, the trial court did not abuse its discretion in awarding Wife attorney's fees. View "Urbaniak v. Urbaniak" on Justia Law

After a one-month old was taken to the hospital with injuries consistent with non-accidental trauma, the State took custody of the child and started an abuse and neglect proceeding. Months later, the child was adjudicated abused or neglected. Following a period of State supervision, the child was returned to Mother, and the abuse and neglect action was dismissed as to both Mother and Father. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in (1) declining to make separate findings regarding Mother's and Father's culpability; (2) finding the child abused or neglected under S.D. Codified Laws 26-8A-2(1) and (3); and (3) declining to alternatively find that the child was abused or neglected under S.D. Codified Laws 26-8A-2(5). View "In re Matter of M.V." on Justia Law

Employee was prosecuted for theft from his Employer, but he was acquitted by a jury. Employee later commenced an action for malicious prosecution against Employer. The trial court granted summary judgment in favor of Employer, concluding (1) Employee did not establish legal causation between Employer's report of theft and the criminal prosecution, and (2) Employee failed to establish the absence of probable cause to prosecute. Employee appealed, arguing that although the decision to prosecute was made by the state's attorney and grand jury, his claim was actionable because Employer did not give full and correct information to the authorities. The Supreme Court affirmed, holding that the trial court did not err where (1) Employer's report was not the legal cause of the prosecution, and (2) Employee identified no facts suggesting that the prosecution was based on such information and that but for such information the decision to prosecute would not have been made by the prosecutor. View "Danielson v. Hess" on Justia Law