Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the circuit court reversing an administrative law judge's (ALJ) decision determining that Appellant was disqualified from receiving reemployment assistance benefits because he was discharged for work-connected misconduct, holding that this Court could not conduct a meaningful appellate review.The ALJ in this case determined that Appellant could not entitled to reemployment assistance benefits because he was discharged for work-related misconduct, as defined by S.D. Codified Laws 61-6-14.1. The circuit court reversed, concluding that Appellant's habit of hugging co-workers did not constitute misconduct. The Supreme Court reversed, holding that because the ALJ failed to enter findings on Appellant's alleged sexual misconduct, this Court could not conduct a meaningful appellate review. View "Bankston v. New Angus, LLC" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for possession of methamphetamine with intent to distribute, in violation of S.D. Codified Laws 22-42-4.3, holding that Defendant was not entitled to relief on his claims of error.Defendant pleaded guilty to possession of methamphetamine with intent to distribute, his second such offense, and the circuit court imposed the twenty-year mandatory minimum sentence established for a second or subsequent offense. Defendant appealed, arguing that the trial court erred in determining that it was unable to deviate from the mandatory minimum sentence. The Supreme Court affirmed, holding that the court did not err in determining that S.D. Codified Laws 22-42-2.5 did not permit the court to deviate from the mandatory minimum sentence because Defendant had failed to provide any information to the State. View "State v. Hirning" on Justia Law

The Supreme Court reversed the decision of the circuit court to grant summary judgment to the Estate of Rose Beadle in this action seeking to determine title to Beadle's investment accounts, holding that the order was void as a matter of law.Pursuant to a court order, Beadle's temporary guardian and conservator altered Beadle's investment accounts to eliminate Travis and Truman Raguse as her beneficiaries. The court issued its order, however, without a hearing and without notice to the beneficiaries. The circuit court approved a final accounting and terminated the guardian/conservatorship. During the probate of Beadle's estate, the Raguses filed petitions to determine title to Beadle's investment accounts. The circuit court granted summary judgment in favor of the Estate on the Estate's petition to determine title. The Supreme Court reversed, holding that because the order authorizing the conservator to remove the beneficiaries on Beadle's accounts was entered without notice to the beneficiaries and without hearting, the order was void as a matter of law. View "In re Estate of Beadle" on Justia Law

The Supreme Court affirmed Defendant's conviction of hunting on private land without permission from the owner, in violation of S.D. Codified Laws 41-9-1, holding that, contrary to Defendant's assertion on appeal, the Legislature intended section 41-9-1 to be a strict liability offense.Specifically, the Supreme Court held (1) the circuit court did not err in denying Defendant's motion to dismiss and motion for reconsideration; (2) Defendant's argument that a mens rea should be read into section 41-9-1 was unavailing; and (3) Defendant's contention that the circuit court initiated an ex parte communication was not supported by the record, and Defendant received a fair and impartial trial. View "State v. Fideler" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court in this divorce action, holding that there was error in the division of the parties' marital property and in the spousal support award.After seventeen years of marriage Husband commenced a divorce against Wife. Wife filed a counterclaim seeking separate maintenance and requesting that the divorce be postponed until she began eligible to receive lifetime TRICARE health care coverage. The trial court granted made an equitable division of marital property, granted Wife a decree of separate maintenance, and awarded her permanent alimony. The Supreme Court reversed in part, holding (1) the circuit court did not abuse its discretion by denying the entry of a divorce decree until after twenty years of marriage and by granting a decree of separate maintenance; (2) the circuit court lacked the authority to enter an equitable division of the marital property in the separate maintenance proceeding; and (3) on remand, the circuit court should consider the question of spousal support in light of the property division. View "Lefors v. Lefors" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court denying the motion for partial summary judgment brought by the Estate of Robert T. Lynch as to its action against Kevin Lynch and entering judgment as a matter of law for Kevin on his counterclaim for conversion, holding that remand was required.The Estate sued Kevin alleging claims for fiduciary fraud, conversion, breach of fiduciary duty, and elder exploitation. Kevin filed a counterclaim alleging conversion, among other claims. After the circuit court denied the Estate's motion for partial summary judgment on its claims against Kevin the court entered judgment as a matter of law for Kevin on his counterclaim. The Supreme Court (1) reversed as to the Estate's claims involving two payable-on-death CDs Kevin deposited in his individual account and directed that, on remand, the circuit court shall enter judgment as a matter of law for compensatory damages plus prejudgment interest on the Estate’s claims for breach of fiduciary duty and conversion; (2) ruled that the Estate's claim for punitive damage on the reversed portion of the judgment was an open question on remand; and (3) otherwise affirmed. View "Estate of Lynch v. Lynch" on Justia Law

The Supreme Court reversed the order of the circuit court suppressing statements made by Defendant during the execution of a search warrant, holding that the circuit court erred in concluding that Defendant's statements to a law enforcement officer during the execution of a search warrant were involuntarily made.Defendant was indicted for one count each of rape in the third degree and sexual contact with a person incapable of consenting. Defendant filed a motion to suppress the statements he made to law enforcement, arguing that his statements were obtained in violation of Miranda v. Arizona, 384 U.S. 436 (1996). The circuit court granted the motion, concluding that Defendant's statements were involuntarily made under the Due Process Clause. The Supreme Court reversed, holding that, based on a review of the totality of the circumstances, the circuit court erred in concluding that Defendant's statements to law enforcement were involuntarily made. View "State v. Ghebre" on Justia Law

The Supreme Court reversed the administrative and circuit court decisions ordering Appellant to repay $14,080 in Pandemic Unemployment Assistance (PUA) benefits that Appellant had received under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), holding that the circuit court erred.After Congress passed the CARES Act creating a temporary, state-administered PUA benefits program for unemployed individuals, Appellant, a self-employed individual who owned a small bed and breakfast, applied for PUA benefits after becoming unemployed "as a result of COVID-19[.]" The Department of Labor and Regulation, Reemployment Assistance Division determined Appellant was eligible for PUA benefits and issued a series of payments totaling $14,080. Later, however, the Department determined that Appellant was not eligible for benefits because she was "not considered unemployed" under any of the bases listed in the CARES Act. The Department then ordered Appellant to repay the PUA benefits. The circuit court affirmed. The Supreme Court reversed, holding that the ALJ erred in applying the causation standard in the Self-Employment Rule and further erred in concluding that Appellant was ineligible for PUA benefits. View "Bracken v. Dep't of Labor & Regulation, Reemployment Assistance Division" on Justia Law

The Supreme Court affirmed the judgment of the circuit court affirming the decision of the Deadwood Historic District Commission to deny a certificate of appropriateness sought by Harlan Kirwan to conduct renovations on a building he owned that was located in the Historic District, holding that there was no error.Kirwan, who owned a saloon located in the Historic District, applied for a certificate of appropriateness from the Commission after renovating the saloon's facade. The Commission denied the application and ordered Kirwan to remove the facade. Kirwan subsequently applied for a new certificate of appropriateness to cover the existing facade. The Commission denied the permit, and the circuit court affirmed. The Supreme Court affirmed, holding that there was no error in the underlying decision. View "Kirwan v. City Of Deadwood" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree burglary, aggravated assault, and grand theft, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held that the circuit court (1) did not commit plain error by allowing a police officer to testify that Defendant invoked his right to an attorney; (2) did not err by denying Defendant's motion for judgment of acquittal concerning the aggravated assault charge; and (3) did not err by denying Defendant's motion for judgment of acquittal concerning his aggravated assault and first-degree burglary charges. View "State v. Robertson" on Justia Law