Justia South Dakota Supreme Court Opinion Summaries

Lita St. John sued Dr. Linda Peterson, alleging medical malpractice in repairing a vesicovaginal fistula. The jury entered a verdict for Peterson. St. John appealed, arguing that the trial court erred in excluding evidence of other cases where Peterson failed to repair vesicovaginal fistulas. The Supreme Court held that the trial court misstated and apparently misapplied the balancing test of S.C. R. Evid. 403, which states that relevant evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice. Because it was possible that the exclusion of the evidence in all probability affected the outcome of the jury's verdict and thereby constituted prejudicial error, the Court reversed the judgment of the trial court and remanded. View "St. John v. Peterson" on Justia Law

Vera Martin, who lived in South Dakota, worked at an American Colloid plant in Wyoming. After suffering a work-related injury at the Wyoming plant, Martin received Wyoming workers' compensation benefits. Martin then filed a claim for South Dakota workers' compensation benefits. The South Dakota Department of Labor dismissed her claim for lack of jurisdiction. The circuit court affirmed. On appeal, the Supreme Court affirmed, holding that (1) while Martin was a South Dakota resident throughout her employment with American Colloid, that fact was not alone sufficient to create the substantial connection necessary to conclude that South Dakota was the place of the employment relationship; and (2) because South Dakota was not the place of the employment relationship, the department did not have jurisdiction over this matter. View "Martin v. American Colloid Co." on Justia Law

When Mother and Father divorced, they agreed pursuant to a parenting plan incorporated into the divorce decree to share custody of Child, with Mother having primary physical custody. Father later moved to obtain primary physical custody. The circuit court granted Father's motion. On appeal, the Supreme Court affirmed, holding (1) the circuit court took a balanced and systematic approach in applying the relevant child custody factors; (2) the circuit court did not clearly err in finding that Father had the ability to provide Child with guidance and good modeling behavior; and (3) the circuit court did not abuse its discretion in choosing one of two conflicting child custody evaluator opinions. View "Simunek v. Auwerter" on Justia Law

The underlying action in this case involved a dispute among a family-owned corporation's shareholders concerning the management and control of the business. The two factions asked circuit court judge John Delaney to determine the corporation's value. Before trial, Delaney entered an order that (1) imposed a gag order on the parties and (2) closed the trial and court records. Several media entities (the Media) petitioned for a writ of mandamus or prohibition, asserting that Delaney's gag order unlawfully interfered with Media's First Amendment and common law rights. The Supreme Court granted Media's request for a permanent writ of prohibition, holding (1) although the underlying trial was complete, Media's claims could be considered under an exception to the mootness doctrine because the issue presented was capable of repetition yet evading review; (2) the First Amendment affords the media and public a qualified right of access to civil trials in the state; (3) Delaney abused his discretion in closing the trial proceedings from the media and public because the procedure and reasoning he used was flawed; and (4) Delaney did not have statutory or legal authority to issue the gag order under the facts and circumstances of this case. View "Rapid City Journal v. Circuit Court (Delaney)" on Justia Law

Appellants, ranchers, owned property in Alto Township separated by a section-line highway. Appellants historically fenced across the highway to join the adjacent pastures and installed gates at the highway. The township requested an injunction requiring Appellants to remove the fences that extended across the highway. Meanwhile, the county board of commissioners passed a resolution authorizing Appellants to erect and maintain fences across the section-line highway if the fences and gates met certain criteria. The trial court then enjoined Appellants from erecting and maintaining fences or gates across the highway unless they met the criteria of the resolution. After Appellants installed cattle guards and gates, the township brought a motion for contempt citation against Appellants, alleging they willfully and contumaciously failed to comply with the trial court's order. The county board of commissioners subsequently determined Appellants had complied with the resolution. The trial court found Appellants in contempt of court. The Supreme Court reversed, holding that the trial court's finding of contempt was clearly erroneous because a reasonable person could conclude that Appellants complied with the trial court's order. View "Alto Township v. Mendenhall" on Justia Law

The South Dakota Public Assurance Alliance (SDPAA), a local government risk pool, negotiated with Aurora County to provide what was essentially insurance coverage. After coverage was finalized, a local dairy farm sued the County over a pre-existing zoning dispute. The County was found liable for damages. SDPAA then sought a declaration that it did not have a duty to defend or indemnify, arguing, inter alia, that the County failed to disclose material facts relating to the claim. In a jury trial, the circuit court excluded as parol evidence the parties' pre-contract communications regarding coverage for zoning issues, including communications that could be interpreted as having disclosed the dairy farm zoning dispute. The jury found for SDPAA. The Supreme Court reversed and remanded for a new trial, holding that because the excluded coverage communications were not offered to alter or contradict any written terms of the agreement, their admission would not have violated the parol evidence rule. View "S.D. Public Assurance Alliance v. Aurora County" on Justia Law

Denise Estes filed suit against Dr. David Lonbaken, a podiatrist, for medical malpractice, alleging that Lonbaken negligently treated a neuroma on her foot and seeking damages. Estes filed the complaint in Buffalo County. Lonbaken moved to change venue to Hughes County, claiming Hughes County was the proper venue because Estes' surgery and follow-up treatment took place in Hughes County. The trial court granted Lonbaken's motion to change venue. At issue on appeal was whether Buffalo County was a proper venue for the action. The Supreme Court affirmed, holding that the facts creating the necessity for bringing the action took place exclusively in Hughes County, and as such, the proper venue was Hughes County. View "Estes v. Lonbaken" on Justia Law

Plaintiffs, a group of children who attended public schools in several South Dakota school districts and their parents and natural guardians, asked for a declaratory ruling that the state's present system of funding education was unconstitutional because it did not provide all children with an adequate and quality education. At issue was (1) S.D. Const. art. 8, 1 & 15, which requires the Legislature to establish and maintain a general and uniform system of public schools and provide funding to secure a thorough and efficient system of common schools throughout the state and (2) whether the legislative scheme for funding education met the constitutional requirements. The circuit court issued a judgment in favor of defendants, holding that the resources, curriculum, and facilities currently provided to students were constitutionally sufficient. The Supreme Court affirmed, holding that the current educational funding system failed to correlate with adequate student achievement to the point of declaring the system unconstitutional. View "Davis v. State " on Justia Law

In 2007, Davison County adopted a county-wide plan to reassess agricultural structures. The County reassessed agricultural structures in four of its twelve townships that year. Donald and Gene Stehly, who owned agricultural structures in the four reassessed townships, initiated a declaratory judgment action, alleging that the plan to reassess four townships each year created an unconstitutional lack of uniform taxation within the county. The trial court concluded that the Stehlys' claim failed because they did not establish lack of uniformity within a single taxing district as required by the South Dakota Constitution. The Supreme Court affirmed, holding (1) townships are taxing districts under the Constitution, and (2) a reassessment plan that creates a temporary lack of uniform taxation among townships within a county is constitutional. View "Stehly v. Davison County" on Justia Law

After self-insured Employer filed for bankruptcy, it continued to take payroll deductions from Employees for medical coverage but stopped paying the provider hospital for the covered charges. The hospital then directly billed Employees for services that should have been paid by Employer. Employees filed suit to stop the hospital's attempts to collect payment, seeking relief under the theories of declaratory judgment, injunction, breach of contract, negligent infliction of emotional distress, and bad faith breach of contract. The circuit court granted summary judgment in favor of the hospital on all of Employees' claims. The Supreme Court reversed, holding (1) Employees had standing as third party beneficiaries to enforce the provisions of the hospital agreement and payer agreement; and (2) Employees were not obligated to pay for covered medical services under the agreements. Remanded. View "Jennings v. Rapid City Reg'l Hosp., Inc." on Justia Law