Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the sentencing court revoking Defendant's suspended sentence, holding that the sentencing court did not abuse its discretion.Pursuant to a plea agreement, Defendant pled guilty to abuse or cruelty to a minor under seven years old. The circuit court sentenced Defendant to ten years' imprisonment, suspended on multiple conditions. The State later moved to revoke Defendant's suspended sentence on the grounds that she had violated a condition of her sentence. The court concluded that Defendant had violated a condition of her suspended sentence and sentenced her to ten years but suspended five years. The Supreme Court affirmed, holding that the sentencing court did not abuse its discretion in revoking the suspended sentence. View "State v. Kari" on Justia Law

The Supreme Court affirmed the order of the circuit court granting summary judgment in favor of Bennie Garber and Dakotaraptor, LLC on this action to quiet title to a section of roadway called Caster's Road filed by Howard and Bonita Nelson and Philip and Evelyn Nelson, holding that the circuit court did not err.The Nelsons bought this action to quiet title and to obtain a judgment declaring that they possess fee title to Caster's Road. The circuit court granted summary judgment for Garber and Dakotaraptor, ruling that Caster's Road was not a public road that the county or township did not maintaining that the Nelsons had no right to control who used the road. The Supreme Court affirmed, holding that the circuit court (1) did not err by considering parol evidence to determine whether Caster's Road is public or private; (2) did not err by holding that the road is a public roadway; and (3) did not err by holding that the Nelsons had no right to control who drives on the road. View "Nelson v. Garber" on Justia Law

The Supreme Court affirmed the judgment of the circuit court reversing the decision of the Department of Labor denying Taylor Hughes's workers' compensation claim for an alleged work-related back injury, holding that the circuit court correctly held that Hughes was entitled to recover for his injury.After a hearing, the Department determined that Hughes had not proven by a preponderance of the evidence that his disability was caused by a workplace injury and that his work activities were a major contributing cause of his disability. The circuit court reversed, determining (1) the Department erred by applying the incorrect standard to the causation of the injury, and (2) the Department's finding that Hughes failed to establish causation was clearly erroneous. The Supreme Court affirmed, holding that the circuit court properly overturned the Department's decision because Hughes proved by a preponderance of the evidence that his injury was work-related and that his employment was a major contributing cause of his current condition. View "Hughes v. Dakota Mill & Grain" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree rape and simple assault, holding that the circuit court did not err when it denied Defendant's motion for a judgment of acquittal on the second-degree rape charge.Specifically, the Supreme Court held (1) there was sufficient evidence to sustain Defendant's conviction for second-degree rape because there was sufficient evidence of "force" as required under S.D. Codified Laws 22-22-1(2); (2) the circuit court did not commit plain error by allowing certain testimony; and (3) the representation provided by Defendant's trial counsel was not constitutionally deficient. View "State v. Townsend" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court concluding that Sierra Club lacked standing to challenge the Clay County Board of Adjustment's decision affirming the issuance of a permit for the operation of a concentrated animal feeding operation in Clay County, holding that the circuit court erred in holding that Sierra Club lacked representational standing.In concluding that Sierra Club lacked standing under S.D. Codified Laws 11-2 to bring this lawsuit in its own right, the circuit court concluded that Sierra Club was not a person aggrieved and lacked representational standing because participation in the suit by its individual members was required. The Supreme Court reversed in part, holding (1) the circuit circuit properly determined that Sierra Club lacked standing to bring suit in its own right under section 11-2-61; and (2) the circuit court erred in concluding that Sierra Club lacked representational standing. View "Sierra Club v. Clay County Board Of Adjustment" on Justia Law

The Supreme Court denied a writ of mandamus requiring the Secretary of State Steve Barnett to appear and show cause why the Supreme Court should not issue a peremptory writ of mandamus directing him to approve Dakotans for Health's form for referral of House Joint Resolution (HJR) 5003 to voters at the general election on November 8, 2002, holding that Petitioner was not entitled to the writ.Petitioner, Dakotans for Health, submitted a petition seeking to refer HJR 5003 to the voters of South Dakota at the November 2022 general election. The Secretary of State refused to file the petition, determining that HJR 5003 did not qualify as a "law which the legislature may have enacted" and that the petition did not have a valid effective date. The Supreme Court denied Petitioner's writ of mandamus, holding that Barnett correctly determined that HJR 5003 does not constitute a law subject to referral and that he had no authority to file the petition. View "Dakotans For Health V. Barnett" on Justia Law

The Supreme Court affirmed the order of the circuit court directing the Sully County sheriff to euthanize two dogs owned by Appellants as "vicious animals" under S.D. Codified Laws 7-12-29, holding that the circuit court did not err.Appellants dogs attacked another dog, which died a few days later from internal injuries and complications fraud an infection caused by the attack. The City of Onida filed a petition for declaratory judgment requesting that Appellants' dogs be determined vicious animals under a city ordinance and, alternatively, sought a determination of dangerousness under section 7-12-29 and requested an order allowing the Sheriff to dispose of the dogs. The circuit court concluded that the City could not require the dogs to be euthanized under the ordnance but found that the dogs were dangerous under the statute and authorized the Sheriff to dispose of the dogs. The Supreme Court affirmed, holding that any error on the part of the circuit court in failing to require consultation with the Department of Health as part of its formal determination of dangerousness was harmless. View "City Of Onida v. Brandt" on Justia Law

The Supreme Court affirmed in part the decision of the circuit court granting partial summary judgment to Plaintiff on his complaint seeking an injunction and restraining order against Plowboy, LLC requiring Plowboy to remove two gates placed across a section-line highway, holding that the circuit court did not err in granting partial summary judgment but erred in directing removal of the gates within twenty days.In his complaint, Plaintiff argued that the gates were unlawful obstructions across a section-line highway. The circuit court concluded that Defendant failed to establish that the road was unimproved, and therefore, the gates must be removed. The court then ordered Defendant to remove the gates within twenty days. The Supreme Court affirmed in part and vacated in part, holding (1) the circuit court did not err in granting partial summary judgment; but (2) the circuit court did not certify its ruling as a final judgment, and therefore, the circuit court was unable to order the removal of the gates within twenty days. View "Patterson v. Plowboy" on Justia Law

The Supreme Court affirmed Defendant's convictions for second-degree murder, first-degree manslaughter, robbery, and additional offenses, holding that the circuit court did not err in overruling Defendant's objection to the inclusion of a jury instruction regarding attempted robbery or by denying Defendant's motion for judgment of acquittal and his motion to arrest judgment.Specifically, the Supreme Court held (1) the circuit court did not err by denying Defendant's motion for judgment of acquittal for second-degree murder or first-degree manslaughter, holding that the convictions were supported by the evidence; and (2) the circuit court did not err by denying Defendant's motion to arrest judgment. View "State v. Frias" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of three felony drug offenses in connection with the sale of methamphetamine to a confidential informant, holding that the circuit court did not abuse its discretion in denying Defendant's motion for a new trial and that Defendant's sentence did not constitute cruel and unusual punishment under the Eighth Amendment.After a two-day trial, Defendant was convicted of three drug-related offenses. Defendant was sentenced to fifteen years imprisonment for the possession and distribution counts, to run concurrently to each other and to the sentences he was serving, and to twenty-five years for the offense of distribution in a drug free zone, to run consecutively to his other sentences. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion by refusing to admit certain evidence proffered by Defendant; (2) the circuit court did not abuse its discretion in denying Defendant's motion for a new trial; and (3) Defendant's sentence was neither grossly disproportionate to his crimes nor cruel and unusual. View "State v. Shelton" on Justia Law