Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing this complaint alleging several breaches related to conduct allegedly occurring in connection with the ownership and operation of a pet grooming business, holding that several causes of action were improperly dismissed.The complaint in this case alleged claims for breach of fiduciary duty, breach of the duty of loyalty, breach of the duty of care, conversion, and unjust enrichment, and a separate cause of action for punitive damages. The circuit court dismissed the complaint in its entirety for failure to state a claim. The Supreme Court largely reversed, holding (1) Plaintiff properly instituted this action against Defendant; (2) the circuit court erred in dismissing the causes of action for breach of the duty of loyalty, breach of the duty of care, conversion, and unjust enrichment; and (3) Plaintiff's request for punitive damages was sufficiently pled. View "Mach v. Connors" on Justia Law

In this tort suit brought against an employer by an employee the Supreme Court affirmed in part and reversed in part the judgment of the circuit court denying both parties' motions for summary judgment, holding that the court erred in denying the employer's motion for summary judgment.The employee in this case died after falling off the roof of a building he was working on for a subcontractor. After the employee's estate brought this tort action the employer moved for summary judgment, asserting that under S.D. Codified Laws 62-3-2, workers' compensation was the estate's exclusive remedy. In response, the estate argued that the exception to S.D. Codified Laws 52.-3-2 for intentional torts applied. The circuit court denied summary judgment for either party. The Supreme Court reversed in part, holding that there was no issue of material of fact in dispute on the question of whether the employer committed an intentional tort in this case. View "Althoff v. Pro-Tec Roofing, Inc." on Justia Law

The Supreme Court affirmed the judgment of the circuit court determining that Healy Ranch, Inc. (HRI) possessed marketable record title to certain real property in Brule County, voiding Bret Healy's notice of claim, and denying HRI's request for attorney fees, holding that there was no error.HRI brought this quiet title action under the South Dakota Marketable Title Act (SDMTA) seeking to defeat Healy's notice of claim to the disputed real property and establish for itself marketable record title to the property. HRI also sought costs and attorneys fees. Healy counterclaimed, seeking to quiet title to the property in the name of Healy Ranch Partnership (HRP). The circuit court granted summary judgment for HRI. The Supreme Court affirmed, holding (1) Healy's notice of claim was timely, but the cause of action was precluded, and the notice should be voided on this basis; and (2) the circuit court's denial of HRI's request for attorney fees was not erroneous. View "Healy Ranch, Inc. v. Healy" on Justia Law

In this action to quiet title to a parcel of land in Brule County the Supreme Court affirmed the summary judgment decision of the circuit court determining that the current possessors of the subject land (Possessors) acquired title by adverse possession and quieting title in their favor, holding that the circuit court properly granted summary judgment on Possessors' adverse possession counterclaim.Healy Ranch Partnership (HRP) commenced this action to quiet title, naming multiple defendants, including Possessors, the previous possessors, and another member of HRP. Possessors filed a counterclaim alleging that they had acquired title through adverse possession. The circuit court determined that Possessors acquired title by adverse possession, deciding motions to dismiss and for summary judgment adversely to HRP. The Supreme Court (1) reversed the circuit court's decision granting the motion to dismiss, holding that the court erred when it applied this Court's decision in Healy v. Osborne, 934 N.W.2d 557 (S.D. 2019), to assess the sufficiency of HRP's complaint; and (2) affirmed the court's decision granting Possessors summary judgment on their adverse possession counterclaim, holding that Possessors established title to the property by adverse possession. View "Healy Ranch Partnership v. Mines" on Justia Law

The Supreme Court affirmed the decision of the South Dakota Public Utilities Commission (PUC) approving the application of Crowned Ridge Wind, LLC for a permit to construct a wind energy farm in northeast South Dakota, holding that the PUC acted within its discretion in this case.After a contested hearing, the PUC issued a written decision approving the permit. Two individuals who lived in rural areas near the project and had intervened to oppose Crowned Ridge's application sought review. The circuit court affirmed. The Supreme Court affirmed, holding (1) neither of the Intervenors' evidentiary claims were sustainable; and (2) even if the Intervenors' claims were preserved for appeal, the PUC acted within its discretion when it denied the Intervenors' challenges to certain testimony. View "Christenson v. Crowned Ridge Wind, LLC" on Justia Law

The Supreme Court affirmed the decision of the South Dakota Public Utilities Commission (PUC) approving the application of Crowned Ridge Wind II, LLC to construct a large wind energy farm in northeast South Dakota, holding that the PUC followed the applicable statutory directives in granting the construction permit and properly determined that Crowned Ridge satisfied its burden of proof under S.D. Codified Laws 49-41B-22.After a contested hearing, the PUC issued a written decision approving the permit. Two individuals who lived in rural areas near the project and had intervened to oppose Crowned Ridge's application sought review. The circuit court affirmed. The Supreme Court affirmed, holding (1) the PUC did not err when it determined that Crowned Ridge met its burden of proof to comply with all applicable laws and rules; and (2) the PUC's findings were not clearly erroneous as they related to crowned Ridge's burden under S.D. Codified Laws 49-41B-22(3). View "Christenson v. Crowned Ridge Wind, LLC" on Justia Law

The Supreme Court affirmed the judgment of the circuit court determining that an offer from Dakota Legends Properties, LLP (DLP) was a bona fide offer that triggered Plaintiffs' right of first refusal to purchase the property, that Plaintiffs had been offered the right of first refusal, and that Plaintiffs did not exercise that right, holding that there was no error.Defendant entered into a lease agreement with Plaintiffs that gave Plaintiffs a right of first refusal to purchase the leased property at the same price and terms of any bona fide offer. After receiving an offer from DLP, Defendant notified Plaintiffs of the offer. Plaintiffs made two offers on the property, which Defendant rejected in favor of DLP's offer. Litigation followed, and the parties filed cross-motions for partial summary judgment about whether DLP's offer was "bona fide." The circuit court granted summary judgment in favor of Defendant, concluding that DLP's offer was a bona fide offer and that Plaintiff had not exercised her right of first refusal. The Supreme Court affirmed, holding that the circuit court's conclusions of law were without error. View "McCoy v. McCallum" on Justia Law

The Supreme Court affirmed the judgment of the circuit court affirming the determination of the Department of Labor and Regulation that Appellant was not permanently totally disabled, holding that Appellant failed to sustain his claim for permanent total disability.While he was employed by Rapid City Regional Hospital (RCRH) Appellant claimed he sustained two work-related head injuries that caused ongoing mental impairments. Appellant sought workers' compensation benefits from RCRH and its insurer, but the Department denied the claim, finding (1) Appellant failed to prove his work injuries were a major contributing cause of his mental impairments, and (2) Appellant failed to establish that he was permanently disabled. The Supreme Court affirmed, holding that the Department and circuit court properly concluded that Appellant was not permanently totally disabled. View "Baker v. Rapid City Regional Hospital" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court determining that Denise Schipke-Smeenk was not entitled to specific performance of an agreement she made with her husband that neither party would revoke their specific wills without the other's consent, holding that the circuit court erred in determining that the claim was not timely or properly presented.Denise and Neil Smeenk executed mutual wills in 2017 and the agreement at issue. In 2019, Neil executed a new will without Denise's consent. After Neil died, the circuit court appointed Denise as personal representative of Neil's estate and ordered the 2019 will to be probated. The circuit court denied Denise's motion seeking specific performance of the agreement, determining that the motion was not properly presented as a creditor claim and was untimely and that Denise was not entitled to specific performance. The Supreme Court reversed in part, holding that the circuit court (1) erred in determining that the claim was not timely and properly presented; but (2) correctly ruled that Denise was not entitled to specific performance. View "In re Estate of Smeenk" on Justia Law

The Supreme Court reversed the order of the circuit court denying Meemic Insurance Company's motion to dismiss this action for lack of personal jurisdiction, holding that the minimum contacts necessary to support the exercise of personal jurisdiction in accordance with due process requirements were not satisfied.Catherine Davis was riding as a passenger on William Laeder's motorcycle when Richard Otten, who was also driving a motorcycle, collided with them. All three people sustained incapacitating injuries. Meemic had issued an insurance policy in Michigan to Davis, which was in effect at the time of the accident. Davis ultimately filed a complaint against Otten and Meemic alleging that Meemic breached its insurance contract with Davis by failing to compensate her under the underinsured motorist coverage and no-fault insurance terms of her policy. After the circuit court denied Meemic's motion to dismiss, Meemic filed a petition for intermediate appeal. The Supreme Court granted the petition and reversed, holding that the minimum contacts required to warrant a finding of jurisdiction were not met in this case. View "Davis v. Otten" on Justia Law