Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court determining that Arthur and Jerilyn Gregg were not estopped from asserting that their son-in-law, Tyler McGregor, had no rights in their cattle, and therefore, First Dakota National Bank did not have a security interest in the Greggs' cattle, holding that the circuit court did not err.Tyler and Rebecca McGregor operated a cattle feedlot, and First Dakota was their lender. In 2015, Tyler agreed to feed 289 head of cattle owned by the Greggs. When First Dakota conducted an inspection of the McGregors' cattle operation, Tyler misled the bank into believing that he owned the Greggs' cattle. First Dakota later filed this declaratory judgment action seeking a judgment against the Greggs for the value of the cattle returned to the Greggs. The court held that the Greggs were not estopped from asserting that the McGregor had no rights in the Greggs' cattle, and therefore, First Dakota could not claim a security interest in them. The Supreme Court affirmed, holding that the evidence did not support the first inquiry necessary to establish an estoppel claim. View "First Dakota National Bank v. Gregg" on Justia Law

The Supreme Court affirmed the decision of the Department of Public Safety to disqualify Appellant's commercial driver's license (CDL) for one year after he pled guilty to driving under the influence (DUI) and received a suspended imposition of sentence, holding that the Department properly disqualified Appellant's CDL.On appeal, Appellant argued that the Department violated the doctrine of separation of powers under the state constitution by unconstitutionally infringing upon the judiciary's sentencing authority and that the Department no longer had the statutory authority to disqualify Appellant's CDL once his case was dismissed and discharged. The Supreme Court affirmed, holding (1) Appellant failed to show that South Dakota's CDL disqualification statutes violate the separation of powers doctrine in article II of the state constitution; and (2) the Department properly considered Appellant's 2016 DUI conviction for the purpose of CDL disqualification under S.D. Codified Laws 32-12A-32. View "Jans v. Department of Public Safety" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Defendants' 2013 motion to enforce a purported settlement agreement and to compel arbitration and dismissing Defendants' claim for unjust enrichment after a trial, holding that the circuit court did not err.Plaintiff brought suit against Defendants, his brothers, to dissolve their family partnership and asserting claims for breach of contract and breach of fiduciary duty. Defendants asserted multiple counterclaims based on Plaintiff's alleged misappropriation of partnership assets. This appeal concerned only the circuit court's denial of Defendants' motion to enforce the settlement agreement and to compel arbitration and the dismissal of Defendants' claim for unjust enrichment. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Defendants' motion to enforce the purported settlement agreement and to compel arbitration; and (2) did not err in denying Defendants relief on their claim for unjust enrichment. View "Paweltzki v. Paweltzki" on Justia Law

The Supreme Court reversed the judgment of the circuit court affirming the decision of the South Dakota Department of Labor and Regulation (Department) concluding that it lacked jurisdiction over Plaintiff's claim seeking workers' compensation benefits, holding that the Department had the authority to adjudicate Plaintiff's claim.Plaintiff was injured in Wyoming while working at a job for Defendant, a corporation formed and headquartered in South Dakota. Plaintiff applied for and received workers' compensation benefits in Wyoming. Later, Plaintiff sought benefits in South Dakota, which has more favorable workers' compensation statutes. The South Dakota Department of Labor and Regulation dismissed the petition, concluding that it lacked jurisdiction. The circuit court affirmed. The Supreme Court reversed, holding that South Dakota had a substantial connection to the parties' employment relationship sufficient to provide the Department with authority to adjudicate Plaintiff's claim. View "Anderson v. Tri State Construction, LLC" on Justia Law

The Supreme Court affirmed the judgment of the circuit court affirming the decision of the Department of Labor and Regulation determining that a copy of a letter to Appellant's insurer seeking a review of his workers' compensation benefits did not constitute a petition for a hearing, holding that the Department and the circuit court did not err.Appellant injured his left and right shoulder at work. Western National Insurance (Insurer), the workers' compensation for Appellant's employers, paid workers' compensation benefits. Five years later, Appellant sent a letter to Insurer seeking a review of his workers' compensation benefits and sent a copy of this letter to the Department requesting that the Department determine that the letter constituted a petition for hearing. The Department concluded that the letter was not a petition for hearing because it lacked the information required by ARSD 47:03:01:02. The circuit court affirmed. The Supreme Court affirmed, holding that the circuit court did not err in concluding that Appellant's letter did not satisfy ARSD 47:03:01:02. View "May v. Spearfish Pellett Co." on Justia Law

The Supreme Court vacated the order of the circuit court granting a petition to terminate a joint tenancy filed with the estate action of one of the deceased tenants without notice or a hearing, holding that the failure to provide notice was not harmless.Specifically, the Supreme Court held (1) this Court had appellate jurisdiction to review the circuit court's order terminating the joint tenancy; (2) the petition to terminate the joint tenancy was a formal proceeding requiring notice, and the failure to comply with the notice requirements was not harmless; and (3) Appellant's argument that he was immediately vested with the joint tenancy land either by the right of survivorship or the provisions of the Uniform Probate Code was not a basis for affirming the order terminating the joint tenancy. View "In re Estate of Petrik" on Justia Law

The Supreme Court dismissed this appeal seeking review of four adverse pretrial decisions after the circuit court granted summary judgment on some of the parties' claims, holding that accepting appellate jurisdiction would lead to piecemeal litigation of the myriad claims among the four parties.When one of three founding members of a cooperative grazing association died, his estate invoked a provision of the bylaws of the association to withdraw real estate that was previously contributed to the association and sell it to a third party. Another member objected, leading to this litigation. The circuit court granted summary judgment to the estate as to certain claims but did not determine all of the various claims among the parties. Two parties appealed, seeking review of four adverse pretrial decisions. The Supreme Court dismissed the appeal, holding that the justification for the S.D. Codified Laws 15-6-54(b) certification was not readily apparent from the record. View "Nelson v. Campbell" on Justia Law

The Supreme Court vacated Defendant's sentence imposed in connection with his guilty plea to first-degree manslaughter, holding that the district court abused its discretion in imposing the sentence.After a confrontation with Lucas Smith at a local bar, Defendant, who was carrying a handgun, encountered Smith in a nearby alley. Smith ran toward Defendant, yelling for Defendant to shoot him. Defendant took a few steps back and then fatally shot Smith. Defendant pled guilty to first-degree manslaughter under the theory that he was "resisting an attempt by [Smith] to commit a crime." The circuit court ultimately convicted Defendant to 124 years in the penitentiary. The Supreme Court vacated the sentence, holding (1) the circuit court overlooked the element of S.D. Codified Laws 22-16-15(4) that contemplates criminal conduct by Smith, which provided partial justification for Defendant's response; and (2) the court's decision to treat Defendant as solely responsible without regard for Smith's conduct was not harmless. View "State v. Mitchell" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court denying both parties' summary judgment motions as to Plaintiff's 42 U.S.C. 1983 claims, holding that the circuit court erred in denying summary judgment in favor of the City of Sioux Falls.Plaintiff brought this action against certain officers of the Sioux Falls Police Department and the City of Sioux Falls. The police officers and the City filed a motion for summary judgment. The circuit court (1) concluded that the officers were not entitled to qualified immunity; (2) denied summary judgment on Plaintiff's claim against the City due to material issues of fact. The Supreme Court held that the circuit court (1) erred in denying summary judgment on Plaintiff's claim that the officers' warrantless entry into her apartment violated her constitutional right to be free from unreasonable searches and seizures; (2) erred in denying the City's motion for summary judgment; and (3) properly concluded that material issues of fact were in dispute on the question of whether the officers used excessive force such that Defendants were not entitled to qualified immunity as a matter of law on this section 1983 claim. View "Boggs v. Pearson" on Justia Law

The Supreme Court affirmed the decision of the circuit court dismissing Appellants' creditor claim against the estate of John Calvin, holding that the circuit court properly dismissed the creditor claim.Calvin was the lifetime beneficiary of the Ben W. Calvin Trust, and Appellants - Calvin's children - were the remainder beneficiaries. After Calvin died, Appellants brought a creditor claim against his estate, alleging that Calvin had received disbursements of principal from the Trust in violation of the terms of the Trust. The circuit court dismissed the creditor claim, concluding that the Trust disbursements to Calvin were proper under the terms of the Trust. The Supreme Court affirmed, holding that Appellants failed to show that they had standing to assert a claim against the Estate. View "In re Estate Of Calvin" on Justia Law