Justia South Dakota Supreme Court Opinion Summaries

In the case before the Supreme Court of the State of South Dakota, the dispute involves a married couple, Michael Erickson and Tara Erickson, who got divorced and had a stipulation and agreement (the Agreement) incorporated into their divorce decree, to settle matters such as child support and custody. Tara claimed the couple's two minor children as dependents on her tax returns since 2018, believing the Agreement allowed her to do so. However, in 2022, Michael argued that he was entitled to claim the children as dependents per the Agreement's language and moved to enforce the Agreement and hold Tara in contempt. In turn, Tara moved to modify the divorce decree and Agreement, alleging a mistake in the language Michael cited.The circuit court found that the provision of the Agreement upon which Michael relied was due to a drafting error, denied Michael’s requests, and granted Tara’s motion to revise the Agreement and her request for attorney fees. The Supreme Court of South Dakota affirmed in part, reversed in part, and remanded for further proceedings. The Court agreed with the circuit court that the Agreement was ambiguous and that, based on the parties' intent shown through parol evidence, Tara was meant to be the one to claim the children as dependents. Therefore, the Court found that Tara did not willfully disobey the court order as Michael alleged. However, the Court reversed the circuit court's award of attorney fees to Tara, finding that it did not make the necessary findings to support the reasonableness of the fees. The case was remanded for further proceedings on this issue. View "Erickson V. Erickson" on Justia Law

In the case brought before the Supreme Court of the State of South Dakota, Elias Richard was convicted of second-degree murder for the shooting death of Vernall Marshall. Richard appealed the decision, arguing that the circuit court erred in allowing evidence of his gang affiliation and in denying his motion for mistrial due to the State’s failure to disclose a forensic report.On Christmas Eve 2020, Richard, along with several others, confronted Marshall regarding inappropriate text messages Marshall had sent to a minor. Richard was part of a gang known as the Dark Side Family, and the confrontation ended with Marshall being shot twice in the back and left for dead. The court allowed reference to Richard’s gang affiliation to explain his involvement in the incident, which was otherwise unconnected to him.Richard also sought a mistrial after it was revealed during trial that the State had not disclosed a forensic report. This report contradicted the defense's opening statement claim that shell casings found at the crime scene matched those found at a co-defendant’s apartment. The court, however, denied the motion, deeming the failure to disclose inadvertent and not prejudicial.On appeal, the Supreme Court affirmed the circuit court's decisions. It concluded that the evidence of Richard’s gang affiliation was relevant to explain his motive for confronting Marshall and did not unfairly prejudice the jury. The court also found that the failure to disclose the forensic report did not materially prejudice Richard's defense, as his primary strategy was to argue that another defendant was the shooter, a theory that was not undermined by the undisclosed report. Therefore, the court held that the circuit court did not err in denying Richard's motion for mistrial. View "State V. Richard" on Justia Law

Austin McGee was involved in a car accident on a stretch of Highway 45 in South Dakota that was undergoing resurfacing. He claimed that the accident was caused by a negligent failure by the South Dakota Department of Transportation (DOT) and several of its employees to ensure that the contractor responsible for the resurfacing complied with DOT standards and industry practices. The DOT argued that sovereign immunity protected it from the lawsuit. The Supreme Court of South Dakota affirmed the lower court's decision that McGee could sue the DOT and its employees, rejecting the DOT's arguments that McGee lacked standing as a third-party beneficiary of the contract between the DOT and the contractor, and that McGee failed to establish an actionable duty. The court found that the DOT had a ministerial duty under its own Standard Specifications not to exceed the estimated amount of tack coating to be applied each day, but found no ministerial duties relating to the use of precautionary measures. Thus, the Supreme Court of South Dakota affirmed in part, reversed in part, and remanded for further proceedings. View "Mcgee V. Spencer Quarries" on Justia Law

In this case heard by the Supreme Court of the State of South Dakota, Ivan and Donita Weber, who were married for less than four years, sought a divorce. Prior to their marriage, Donita owned significant assets, including a valuable farmland. During their marriage, the couple co-mingled and jointly titled most of their assets, including the farmland. They worked on and made improvements to the farm before selling it and most of the accompanying assets for approximately $2.5 million. Upon divorce, the circuit court treated most of the parties’ property as marital but awarded Donita a much larger share. Ivan appealed, arguing that the circuit court abused its discretion in dividing the marital assets and in failing to award him spousal support.The Supreme Court of the State of South Dakota affirmed the lower court's decision. The court found that the circuit court appropriately considered the relevant factors, including the duration of the marriage, the value of the property owned by the parties, their ages, health, ability to earn a living, the contribution of each party to the accumulation of the property, and the income-producing capacity of the parties’ assets. The court found that the circuit court did not abuse its discretion in dividing the marital property, given the short length of their marriage and the fact that Donita brought in significantly more assets into the marriage than Ivan.Regarding Ivan's argument for spousal support, the court found that Ivan had waived his right to appeal this issue because he failed to present any issue concerning spousal support to the circuit court. Therefore, the court declined to award Ivan any attorney fees and awarded $5,000 in appellate attorney fees to Donita. View "Weber V. Weber" on Justia Law

In this case, the defendant, Manegabe Chebea Ally, was convicted of first-degree manslaughter for the death of a 16-month-old child. He was sentenced to a 45-year prison term with 20 years suspended. Following his conviction, Ally appealed, alleging that his trial counsel was ineffective in several respects. After a series of evidentiary hearings, the habeas court granted him relief, determining that his counsel was indeed ineffective and that the cumulative effect of these deficiencies prejudiced his defense. The habeas court determined that Ally's right to a fair trial was violated.The Supreme Court of the State of South Dakota, however, reversed the decision of the habeas court. The Supreme Court found that while Ally's counsel's opening statement included an imprecise remark, this mistake did not undermine the adversarial process or deprive Ally of a fair trial. The Court also found that Ally's defense counsel made a reasonably strategic decision to exclude parts of Ally's three interviews with a detective and to not elicit additional testimony from a medical expert. Although the Court acknowledged that the defense counsel's failure to disclose a certain video to the prosecutor deviated from prevailing professional norms, it did not result in significant prejudice to Ally. The Court therefore concluded that Ally did not receive ineffective assistance of counsel at his 2012 trial, and the decision of the habeas court was reversed. View "Ally V. Young" on Justia Law

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