Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the circuit court granting summary judgment in favor of Jeffrey Cole, William Sims, and Gregory Brewers (collectively, the Attorneys) arising out the Attorneys' representation of Doug and Dawn Barr in a personal injury action, holding that the circuit court did not err.The Barrs, husband and wife, were involved in a motor vehicle accident with Stuart Hughes. The Attorneys filed a lawsuit on behalf of the Barrs against Hughes. Following the settlement of their personal injury claims, the Barrs sued the Attorneys for legal malpractice and related claims, challenging the Attorneys' alleged failure to pursue a claim for damages against the State for Hughes's negligence and the Attorneys' failure to inform them of their claim before they agreed to settle. The circuit court granted summary judgment for the Attorneys. The Supreme Court affirmed, holding that summary judgment was properly granted because the Barrs could not have asserted a claim against the State in their underlying negligence action, and the Attorneys were not negligent for failing to pursue one. View "Barr v. Cole" on Justia Law

The Supreme Court affirmed the decision of the circuit court granting summary judgment in favor of State Farm Mutual Automobile Insurance Company in this lawsuit it brought seeking a declaration that it had no duty to defend or indemnify its insureds under the circumstances, holding that the circuit court did not err.Agtegra Cooperative brought the underlying lawsuit alleging that Mike Grunewaldt and Nancy Grunewaldt were liable to Agtegra for damages related to its delivery of wheat contaminated with fertilizer to Agtegra's elevator. State Farm, the Grunewaldts' insurance company, then commenced a separate lawsuit arguing that it had no duty to defend or indemnify the Grunewaldts to pay any judgment arising from the allegations in Agtegra's action. The circuit court granted summary judgment for State Farm. The Supreme Court affirmed, holding that the circuit court properly held that State Farm had no duty to defend or indemnify the Grunewaldts in the lawsuit initiated by Agtegra. View "State Farm v. Grunewaldt" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree manslaughter and sentencing her to forty years in prison with twenty years suspended, holding that Defendant was not entitled to relief on her allegations of error.Specifically, the Supreme Court held (1) the circuit court did not abuse its discretion when it denied Defendant's motion for a new trial based on an alleged violation of Brady v. Maryland, 373 U.S. 83 (1963); (2) there was sufficient evidence from which a jury could find Defendant guilty of first-degree manslaughter, as defined in S.D. Codified Laws 22-16-15(4); and (3) the circuit court did not abuse its discretion in sentencing Defendant. View "State v. Peltier" on Justia Law

The Supreme Court affirmed the judgment of the habeas court dismissing Appellant's petition for a writ of habeas corpus, holding that the court correctly applied res judicata to determine that Appellant could not demonstrate prejudice as to his ineffective assistance of counsel claim.Appellant pled guilty to first-degree manslaughter and was sentenced to life imprisonment. In his petition for a writ of habeas corpus, Appellant argued that he was actually innocent and that his trial counsel rendered ineffective assistance by not assuring that he understood his right to assert a claim of self-defense. In granting the State's motion to dismiss, the habeas court concluded that Appellant's claims were precluded from relitigation under the doctrine of res judicata because the Court had previously considered them on direct appeal. The Supreme Court affirmed, holding that the habeas court did not err in applying res judicata to determine that Appellant could not demonstrate prejudice under Strickland v. Washington, 466 U.S. 668 (1984). View "Ceplecha v. Sullivan" on Justia Law

In this will contest, the Supreme Court reversed the decision of the circuit court on remand granting Bender's renewed motion for judgment as a matter of law and motion for a new trial, holding that the jury verdict should be reinstated.Upon the death of Russell Tank, Jason Bender, Russell's neighbor and farm tenant, offered Russell's last will and testament, which named Bender as the Estate's sole heir and personal representative, for probate. Plaintiffs, Russell's four children, brought this action challenging the validity of the will based on a lack of testamentary capacity, insane delusions, and undue influence. The Supreme Court granted summary judgment against Plaintiffs. The Supreme Court remanded on the undue influence claim brought by daughter Sherri Castro. The jury returned a verdict for Sherri, finding that Bender unduly influenced Russell's will. The circuit court granted Bender's motion for judgment as a matter of law and motion for new trial on the grounds that there was insufficient evidence to support the jury's verdict. The Supreme Court reversed, holding that Bender unduly influenced the will and that Bender must be removed from serving as personal representative of Russell's Estate. View "In re Estate of Tank" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of the South Dakota Department of Transportation (DOT) in the underlying action alleging that a newly-constructed median in the highway abutting property owned by Legacy Land Company effected a taking entitling it to compensation, holding that there was no error.The DOT constructed the median at issue as part of a highway improvement project. While the median did not eliminate access to the property owned by Legacy, it did change the access because vehicles could no longer make a left turn directly into the Legacy property and those leaving the property could only turn right onto the highway. The district court granted summary judgment for the DOT. The Supreme Court affirmed, holding that, although the median's construction affected the ease with which vehicles traveling east could access Legacy's property, the record did not support Legacy's claim that the median substantially impaired its right of access. View "S.D. Dep’t Of Transportation v. Legacy Land Co." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court granting the motion brought by Robert and Shannon Bathurst to dismiss the underlying lawsuit because a statute of limitations barred Linda Paul from bringing her claim against them, holding that dismissal was improper.Paul brought this action against Robert, Shannon, and Stonemeadow Ranch, LLC, alleging breach of contract, quantum merit, unjust enrichment, and promissory estoppel. Shannon and Robert moved to dismiss for failure to state a claim and, in the alternative, argued that Paul's claims were time-barred by the statute of limitations set forth in S.D. Codified Laws 15-2-15(4). The Supreme Court applied a two-year statute of limitations and granted the motion to dismiss based on the alternative argument of the statute of limitations. The Supreme Court reversed in part, holding (1) the record did not allow a determination of which statute of limitation applied at this early stage of the proceedings; and (2) the circuit court did not err when it denied the motion to dismiss for failure to state a claim upon which relief could be granted. View "Paul v. Bathurst" on Justia Law

The Supreme Court vacated a portion of the circuit court's decision concerning public comment at some of the board meetings held by Rapid City Area School District 51-4 (RCAS) and affirmed the court's decision not to review a determination made by a state's attorney concerning an alleged violation of a separate open meeting statute, holding that the first issue was nonjusticiable.Plaintiffs commenced this action against RCAS seeking a declaration that RCAS was acting contrary to South Dakota's open meeting law by not allowing public comment at some of its board meetings. The circuit court granted summary judgment in favor of RCAS and concluded that it could not review the state's attorney's determination. The Supreme Court (1) vacated the portion of the circuit court's decision concerning public comment, holding that there was no longer a live controversy regarding the interpretation of "regularly scheduled official meeting" as used in S.D. Codified Laws 1-25-1, and therefore, the issue was moot; and (2) affirmed the court's decision not to review the state's attorney's determination, holding that S.D. Codified Laws chapter 1-25 did not confer jurisdiction upon circuit courts to review the actions of a state's attorney taken under S.D. Codified Laws 1-25-6. View "SD Citizens For Liberty, Inc. v. Rapid City Area School" on Justia Law

The Supreme Court reversed the decision of the circuit court granting summary judgment for Lakota Lakes and denying Emily Bialota's cross-motion for summary judgment in this quiet title action, holding that Bialota accomplished valid service on the Minnesota Secretary of State.Bialota brought an action to quiet title in Pennington County, alleging that she had fee simple ownership in real property previously owned by Lakota Lakes but later sold at a tax sale. In its summary judgment motion, Lakota Lakes claimed that it had not been validly served with the notice of intent to take tax deed, rendering the tax deed void. In her cross-motion for summary judgment, Bialota argued that service upon Lakota Lakes was proper and that Pennington County had correctly issued a tax deed based upon her affidavit of completed service. The Supreme Court reversed, holding (1) South Dakota law controlled this Court's determination whether Bialota personally served the Secretary as Lakota Lakes' registered agent; (2) Bialota accomplished valid service on the Secretary; and (3) Bialota was entitled to the tax deed to the property. View "Bialota v. Lakota Lakes, LLC" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying the State's motion to dismiss the second petition for a writ of habeas corpus filed by David Lee in 2004, holding that Lee's claim for habeas relief must be denied.Lee brought his second habeas corpus petition in 2004, alleging that his habeas counsel was ineffective for failing to seek a certificate of probable cause in his first habeas corpus proceeding. It wasn't until 2019, however, that Lee served the State with the provisional writ. The State moved to dismiss the writ, arguing that after the expiration of the statutory 30-day period for filing a motion for a certificate of probable cause under S.D. Codified Laws 21-27-18.1, the court did not have the authority to issue a certificate of probable cause. The circuit court denied the motions to dismiss. The Supreme Court reversed, holding (1) Lee had no right to appeal absent a certificate of probable cause issued by the habeas court or a member of the Supreme Court, and Lee had no right to a certificate of probable cause; and (2) even if Lee's habeas counsel was ineffective, it did not deprive Lee of any constitutional or statutory right that may be vindicated in a habeas corpus proceeding. View "Lee v. Weber" on Justia Law