Justia South Dakota Supreme Court Opinion Summaries

A family dispute over ownership of a South Dakota ranch led to extensive litigation between a corporation (HRI), a partnership (HRP), and individual family members, including Bret Healy. HRI, owned by three brothers in equal shares, petitioned for court-supervised dissolution after the board and a majority of shareholders voted in favor. Bret, representing HRP, filed a motion to dismiss the petition, asserting that HRP owned a majority of HRI’s stock and that the required shareholder approval for dissolution was lacking. This assertion contradicted prior factual findings in earlier related cases, which consistently determined that ownership claims advanced by Bret or HRP had been previously resolved against them.The Circuit Court of the First Judicial Circuit, Brule County, South Dakota, issued an order to show cause regarding possible violations of SDCL 15-6-11(b) (the South Dakota rule analogous to Rule 11), focusing on whether Bret and his attorney, Volesky, submitted unsupported or false filings for improper purposes. After briefing and a hearing, the circuit court found that Bret violated SDCL 15-6-11(b)(1) by acting with improper purpose, and that Volesky violated multiple subsections. The court imposed monetary sanctions of $240,000 against Bret and $10,000 against Volesky, and reported Volesky to the disciplinary board.On appeal, the Supreme Court of South Dakota affirmed the finding that Bret’s conduct was sanctionable under SDCL 15-6-11(c), concluding that his repeated litigation over ownership, despite numerous adverse rulings, was for improper purposes. However, the Supreme Court vacated the monetary sanction against Bret and remanded for a new hearing. The court held that, in determining sanctions, a trial court must consider the party’s ability to pay and whether non-monetary sanctions or a combination would be appropriate. The affirmation of sanctionable conduct was thus upheld, but the amount and type of sanction require further consideration. View "Dissolution Of Healy Ranch, Inc." on Justia Law

A minor, J.A.D., was charged as a juvenile delinquent in South Dakota after threatening to shoot a school counselor, other students, and himself, during a conversation with a school official. These statements, made at school, led staff to initiate a soft lockdown and notify law enforcement. J.A.D. left the school, was later located at his grandfather’s home, and was arrested. The State charged him with aggravated assault, simple assault, and making a terrorist threat; the aggravated and simple assault charges were presented as alternatives.The Circuit Court of the Seventh Judicial Circuit found J.A.D. not delinquent on aggravated assault, concluding the State had not established use of a deadly weapon or imminence of harm. However, the court found him delinquent on the simple assault and terrorist threat charges, determining that his statements constituted a credible threat and placed the counselor in fear, and that he threatened a crime of violence with the intent to impair a public service. For disposition, the court committed J.A.D. to the Department of Corrections, finding that less restrictive alternatives were not viable due to his prior unsuccessful treatments and risk to public safety.On appeal, the Supreme Court of the State of South Dakota reviewed whether the evidence supported findings of simple assault and making a terrorist threat, and whether commitment to the Department of Corrections was proper. The Supreme Court held that the evidence was insufficient to sustain the simple assault adjudication because J.A.D.’s threat was not imminent, but affirmed the adjudication for making a terrorist threat, finding sufficient evidence of a specific intent to substantially impair a public service. The Supreme Court also affirmed the commitment to the Department of Corrections, holding that the circuit court’s findings were not clearly erroneous and that it did not abuse its discretion. View "Interest Of J.A.D." on Justia Law

The dispute centers on a property in Sioux Falls owned by Charles and Heather Gustafson, located near the intersection of 41st Street and Carolyn Avenue. The State of South Dakota initiated a condemnation action in 2020 to acquire portions of the Gustafsons’ property for the reconstruction of the Interstate 29 and 41st Street interchange. As part of the project, the State permanently closed the intersection of 41st Street and Carolyn Avenue, eliminating the most direct access route from 41st Street to the Gustafsons’ property. The Gustafsons asserted that this closure significantly impaired access to their property, diminishing its value, particularly for high-traffic commercial uses.The Second Judicial Circuit Court reviewed the case after the Gustafsons argued that the loss of access was compensable. Following a court trial, the circuit court found the Gustafsons had a special right of access to 41st Street through the Carolyn Avenue intersection, that the closure caused a substantial impairment unique to their property, and that the injury was peculiar, not merely shared by the general public. The court therefore ruled that the change in access was compensable and the Gustafsons were entitled to seek just compensation for this loss. The State appealed, challenging these conclusions.The Supreme Court of the State of South Dakota reversed the circuit court’s decision. It held that the Gustafsons did not retain a special right of access to 41st Street or the Carolyn Avenue intersection, as their predecessors had relinquished such rights in a 1958 agreement. The Court further determined that the closure did not substantially impair the Gustafsons’ reasonable access to the general road system, and any inconvenience or increased travel distance was shared by the public at large, not unique to their property. As a result, the closure was not compensable. View "Dept. of Transportation v. Gustafson" on Justia Law

Chadwick Janes was convicted of abuse or cruelty to a minor involving his stepchild, B.S. The case arose after Janes’s stepchildren and biological child disclosed physical abuse to their mother and grandmother, prompting a police report and subsequent forensic interviews at a child advocacy center. The children described incidents such as being beaten with a belt, choked, and pushed. The State charged Janes with aggravated assault and abuse or cruelty to a minor, ultimately dismissing one count before trial.The Circuit Court of the Second Judicial Circuit in Minnehaha County, South Dakota held pretrial hearings regarding the admissibility of hearsay and other act evidence, excluding some evidence but permitting others under specific statutory exceptions. At trial, additional evidence—some previously excluded or not addressed—was admitted without objection, including a forensic interview and supplemental report. The jury acquitted Janes of aggravated assault but convicted him of abuse or neglect of a child. The circuit court sentenced Janes to ten years imprisonment with three years suspended and ordered restitution for Tanya’s lost wages and future counseling costs for the children, although the written judgment did not include counseling costs.On appeal to the Supreme Court of the State of South Dakota, Janes raised issues regarding evidentiary errors, sentencing, restitution, and ineffective assistance of counsel. The Supreme Court applied plain error review and found no prejudice from the admission of disputed evidence, as much was cumulative to trial testimony. The Court affirmed Janes’s sentence and the restitution order for Tanya’s lost wages, finding sufficient evidence of causation. However, it reversed the restitution order for future counseling expenses because the amount was unascertainable and unsupported by evidence, remanding for a proper hearing. The Court rejected the ineffective assistance claim, as no prejudice was established. View "State v. Janes" on Justia Law

Wells Fargo initiated a lawsuit to collect credit card debt from a woman identified as Mary Myers (Mary 1) based on a consumer agreement and supporting documentation that included her address, date of birth, and the last four digits of her social security number. The company provided directions for service to the Lawrence County Sheriff, but the deputy mistakenly served a different woman with the same name (Mary 2) at a different address. Mary 2, who was not the debtor, retained counsel and notified Wells Fargo’s attorney of the error, demanding dismissal and reimbursement of legal expenses.After receiving no response from Wells Fargo’s attorney, Mary 2’s counsel filed motions to dismiss and for sanctions under Rule 11 of the South Dakota Rules of Civil Procedure. Wells Fargo’s attorney explained that he had conducted due diligence before filing the complaint and, after reviewing further information, believed he had filed against the correct person. The Circuit Court of the Fourth Judicial Circuit found that Wells Fargo’s attorney violated Rule 11 by not communicating with Mary 2’s attorney after being informed of the mistaken service and by not rectifying the error. The court dismissed Mary 2 from the lawsuit and ordered Wells Fargo to pay her attorney’s fees as a sanction.The Supreme Court of the State of South Dakota reviewed the award of attorney’s fees. It held that Rule 11 sanctions apply only to the filing, signing, or advocacy of documents presented to the court, not to all attorney conduct within litigation. The court concluded that Wells Fargo’s complaint had evidentiary support against Mary 1, and the mistaken service on Mary 2 did not render the pleading sanctionable. Therefore, the Supreme Court reversed the award of attorney’s fees, finding that the circuit court abused its discretion by misapplying Rule 11. View "Wells Fargo v. Myers" on Justia Law

A plaintiff was injured in a collision at an intersection controlled by a malfunctioning traffic signal. Both drivers claimed to have stopped at the flashing red light and to have the right of way. The defendant was driving a truck for his employer, who was also named in the suit under the doctrine of respondeat superior. The plaintiff alleged negligence by the truck driver in failing to maintain control, keep a proper lookout, and yield, and sought damages for injuries and loss of consortium. The employer denied negligence and asserted contributory negligence by the plaintiff.The Circuit Court of the Second Judicial Circuit, Lincoln County, South Dakota, granted the employer’s motion to exclude two of the plaintiff’s expert witnesses, finding their testimony would not aid the jury. The court also denied the plaintiff’s motion to amend the complaint shortly before trial, which sought to add direct negligence claims against the employer and violations of Federal Motor Carrier Safety Regulations (FMCSRs). Additionally, the court refused a jury instruction on those regulations. At trial, the jury found the defendant negligent but determined the plaintiff was contributorily negligent to a degree greater than slight, awarding no damages.The Supreme Court of the State of South Dakota reviewed the appeal. It held that the circuit court did not abuse its discretion in denying the motion to amend as to direct negligence claims against the employer due to untimeliness and prejudice, but erred in denying amendment as to the truck driver’s alleged FMCSR violations, since those allegations provided statutory grounds for existing negligence claims and were not prejudicial or futile. The Supreme Court also held that excluding the expert testimony was an abuse of discretion, as it would have assisted the jury, and that refusal to instruct the jury on FMCSRs was erroneous. The judgment was affirmed in part and reversed in part. View "Hamer V. Duffy" on Justia Law

A truck driver, acting as an agent for a trucking company, was involved in a collision with a vehicle driven by Bianca Spotted Thunder, which was insured under her father’s Liberty Mutual policy. After obtaining an unsatisfied default judgment against Bianca, the trucking company sought recovery from Liberty Mutual under the Spotted Thunders’ policy. Liberty Mutual had previously paid collision coverage but denied liability coverage, citing lack of cooperation from its insureds in the investigation and lack of notice regarding the lawsuit against Bianca.The Circuit Court of the Seventh Judicial Circuit, Pennington County, initially granted Liberty Mutual’s motion to dismiss for failure to state a claim, finding that notice of the suit was a prerequisite to coverage. On appeal, the Supreme Court of South Dakota reversed, holding that a third-party claimant need not plead satisfaction of conditions precedent in the complaint. On remand, Liberty Mutual moved for summary judgment based on noncompliance with policy conditions requiring cooperation and notice. The circuit court granted summary judgment, concluding there were no material facts in dispute regarding noncompliance.The Supreme Court of South Dakota reviewed the matter and clarified that while an insurer may raise noncompliance with policy conditions as a defense in a direct action, South Dakota’s financial responsibility statutes make liability coverage up to statutory minimums “absolute,” barring defenses based on policy conditions for that minimum coverage. However, insurers retain such defenses for excess coverage above statutory requirements. The court affirmed summary judgment in favor of Liberty Mutual for any excess coverage but reversed as to the mandatory minimum coverage required by statute, remanding the case for amended judgment in accordance with this distinction. View "Kaiser Trucking, Inc. V. Liberty Mutual" on Justia Law

The case involves a defendant who was charged with first-degree murder after the fatal shooting of an individual at a bar. The investigation initially yielded no suspect, but the defendant voluntarily approached police, admitted being present at the scene, and expressed concern about possibly doing something “bad.” Over several days, police recovered relevant evidence, including a firearm and clothing linked to the defendant, and conducted multiple interviews. After a polygraph test indicated deception, detectives confronted the defendant, leading to a confession. The defendant was subsequently indicted, and his counsel moved to suppress the confession, arguing it was coerced and a false confession.The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, denied the suppression motion, finding the confession was not the result of improper coercion. Defense counsel then disclosed a forensic psychiatrist, Dr. Manlove, as an expert on false confessions. The State objected to the admissibility of Dr. Manlove’s testimony under Daubert v. Merrell Dow Pharmaceuticals, Inc., and requested a Daubert hearing. After the hearing, the circuit court allowed Dr. Manlove’s testimony on certain general topics related to false confessions but imposed restrictions prohibiting him from relating his testimony to the specific facts of the case or opining that the defendant’s confession was coerced.The Supreme Court of the State of South Dakota reviewed the circuit court’s evidentiary ruling. Applying the abuse of discretion standard, the Court held the circuit court erred by admitting Dr. Manlove’s testimony. The Court found the proffered expert opinions lacked reliability and relevance under Rule 702 and Daubert, and that the testimony was not helpful to the jury given the restrictions imposed and absence of a reliable methodology. The Supreme Court reversed the circuit court’s order permitting the expert testimony and remanded for further proceedings. View "State V. Huante" on Justia Law

A patient in his mid-thirties, with a history of neurological complaints but no similar recent issues, was hospitalized twice in early April 2018 for severe testicular pain at a regional medical center. During the second admission, he received high doses of opioid medications, with documented warnings about their risks and instructions for monitoring his respiratory function. On the last day of his hospitalization, he exhibited abnormal drowsiness and a low respiratory rate. Shortly after discharge, his wife observed sudden, profound cognitive and behavioral changes, including confusion, speech difficulties, and memory problems. Over the following months, he underwent multiple neurological and psychiatric evaluations, many of which failed to show physiological brain abnormalities. Several providers ultimately diagnosed him with functional neurological (conversion) disorder, while a brain injury rehabilitation center noted a history of hypoxia based on family accounts.The patient and his wife filed a medical malpractice suit against the hospital and a treating physician in the Circuit Court of the Third Judicial Circuit, Beadle County, South Dakota. They alleged negligent overprescription of opioids and inadequate monitoring, resulting in a hypoxic brain injury. The defendants moved to exclude the plaintiffs’ causation expert, arguing that his methods were unreliable under Daubert and state law. The circuit court excluded the expert’s testimony and granted summary judgment for the defendants, reasoning that without expert causation testimony, the plaintiffs could not establish a genuine issue of material fact.On appeal, the Supreme Court of the State of South Dakota reviewed whether the exclusion of the expert’s testimony and the grant of summary judgment were proper. The court held that the circuit court erred by failing to assess the reliability of the expert’s overall differential diagnosis methodology and by excluding all his opinions based solely on certain quantitative tests. The Supreme Court reversed the exclusion of most of the expert’s testimony (except regarding two specific tests) and reversed summary judgment, allowing the case to proceed. View "Walton V. Huron Regional Medical Center" on Justia Law

A businessman and rancher in South Dakota, after dating a Colorado horse breeder for nearly a year, proposed marriage. Shortly before the wedding, he presented her with a prenuptial agreement drafted by his attorney. The agreement waived her right to any share of his estate after his death. The parties signed the agreement at the attorney’s office minutes before their civil ceremony. They were later married in Italy and had two children. The businessman died approximately eight years later. The surviving spouse then petitioned for an elective share of the estate and a family allowance, claiming her signature on the agreement was involuntary and the agreement was unconscionable.The Fourth Judicial Circuit Court of Dewey County, South Dakota, held a trial on her petition. The court granted her request for a family allowance but denied her petition for an elective share. The court found she voluntarily signed the agreement and that it was not unconscionable, emphasizing her education, business experience, and opportunity to review the agreement or consult independent counsel. The court also found that the financial disclosures provided were fair and reasonable, and that the terms of the agreement, including a provision for her in the event of divorce, were not disproportionate or unjust. Stephanie appealed the denial of her elective share.The Supreme Court of South Dakota reviewed the case and affirmed the lower court’s decision. The Court held that the prenuptial agreement was voluntarily executed and was not unconscionable under South Dakota law. It found no clear error in the circuit court’s factual findings and determined that the financial disclosure and circumstances surrounding execution of the agreement satisfied statutory requirements. The Supreme Court affirmed the validity and enforceability of the prenuptial agreement and the waiver of the elective share. View "Estate Of Webb" on Justia Law