Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the circuit court denying Appellant's motion for order to show cause why Appellee was not in contempt of the circuit court's judgment and decree of divorce, holding that the circuit court erred when it found that Appellee was not in contempt of court because she was not personally served with the judgment.The circuit court found that Appellee did not comply with a court order but that she could not be found in contempt because she was not given proper notice of the order. The Supreme Court reversed, holding (1) the issue raised on appeal was not moot; and (2) the circuit court clearly erred when it found that Appellee was not in contempt of the order at issue because she did not have knowledge of the contents of the judgment and decree of divorce. View "Metzger v. Metzger" on Justia Law

The Supreme Court affirmed Defendant's sentence to life imprisonment without the possibility of parole in connection with his plea of guilty to aiding and abetting first-degree manslaughter, holding that Defendant's sentence of life without parole was neither an abuse of discretion nor gross disproportionality.On appeal, Defendant challenged his sentence. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion by sentencing Defendant to life in prison without the possibility of parole; and (2) the circuit court's sentence did not amount to cruel and unusual punishment in violation of the Eighth Amendment. View "State v. Klinetobe" on Justia Law

The Supreme Court affirmed Defendant's convictions for vehicular homicide and driving under the influence, holding that the evidence was sufficient to support the convictions and that the circuit court's error in denying Defendant's motion to suppress was harmless.On appeal, Defendant argued that the circuit court erred when it denied her motion to suppress a statement that she made to law enforcement officers at the hospital and when it denied her motion for a judgment of acquittal. The Supreme Court affirmed, holding (1) the circuit court erred by denying Defendant's suppression motion, but the error was harmless given the overwhelming evidence against her; and (2) the evidence was sufficient to sustain Defendant's convictions. View "State v. Angle" on Justia Law

The Supreme Court reversed the judgment of the circuit court reversing the judgment of the Department of Public Safety ordering Appellee's commercial driving privileges to be disqualified for one year, holding that commercial driver's license (CDL) disqualification under S.D. Codified Laws 32-12A-36(4) applies when a vehicle is used as a means to possess a felony quantity of marijuana.The Department disqualified Appellee's commercial driving privileges for one year pursuant to 32-12A-36(4) because he had been convicted of a felony committed in a vehicle by a CDL holder. The circuit court reversed Appellee's CDL disqualification, holding that the statute requires that a vehicle was an "instrumentality" of the felony. The Supreme Court reversed and reinstated the Department's decision, holding (1) possession of a felony quantity of marijuana in a vehicle is "using a...vehicle in the commission of any felony" under section 13-21A-36(4); (2) the circuit court erred by holding that section 13-21A-36(4) was unconstitutionally vague; and (3) there was sufficient evidence to support the Department's disqualification of Appellee's CDL privileges. View "Ibrahim v. Department Of Public Safety" on Justia Law

The Supreme Court reversed the judgment of the circuit court affirming the decision of the Department of Labor and Regulation denying Steven Billman's application for permanent total disability benefits, holding that the Department's determination that Billman was not obviously unemployable was clearly erroneous.During his employment, Billman suffered a work-related injury that required the amputation of his left leg just below the knee. The Department denied Billman's application for benefits, finding that Billman was not obviously unemployable and that he failed to conduct a reasonable job search. The circuit court affirmed the Department's findings. The Supreme Court reversed, holding that Billman established that he was obviously unemployable, and therefore, he was entitled to odd-lot disability benefits. View "Billman v. Clarke Machine, Inc." on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Insureds' motion for attorney fees after they prevailed in their claims against Insurer, holding that the circuit court properly declined to award Insureds' requested attorney fees.A jury returned a verdict in favor of Insureds on their claims of breach of contract and tortious breach of good faith and fair dealing arising out of Insurer's failure to pay for property damage sustained after a hail and wind storm. Insureds filed a motion for attorney fees, arguing that Insurer's disallowance of their claim was vexatious and unreasonable and in violation of the Unfair Trade Practices Act. The trial court denied Insureds' request, concluding that the circuit court could not award attorney fees without a jury determination that Insurer had engaged in an unfair trade practice. The Supreme Court affirmed, holding that the circuit court did not err in declining to award attorney fees. View "Sentell v. Farm Mutual Insurance Co." on Justia Law

The Supreme Court reversed the order of the circuit court applying the doctrine of equitable tolling, thus allowing Noreen French to bring an action against the Estate of Norman D. French to enforce a contract for deed relating to the sale of two quarter sections of farmland, holding that the circuit court erred in applying the doctrine of equitable tolling.Norman French, who farmed two quarters of land in Beadle County, entered into a contract for deed with Alan and Noreen French, his son and daughter-in-law, to sell them the land for $10,000. Noreen continued to farm the two quarters after both Norman and Alan passed away. When Noreen learned that Norman had never conveyed the two quarters, the Estate commenced an action to discharge the contract for deed. The circuit court denied the Estate's petition. Noreen then filed this action alleging that she satisfied her obligations under the contract for deed and requesting that the court order the Estate to deliver a deed conveying legal title to the two quarters of farmland. The Supreme Court reversed, holding that the court's decision to apply the doctrine of equitable tolling was not sustainable. View "In re Estate of French" on Justia Law

The Supreme Court reversed Defendant's conviction of driving under the influence of an alcoholic beverage (DUI), holding that the circuit court erred in denying Defendant a preliminary hearing.The State charged Defendant with driving a motor vehicle while under the influence of an alcoholic beverage. Defendant moved for a preliminary hearing. The circuit court denied the motion. The State then filed a supplemental information alleging that Defendant had been convicted of two prior DUIs, thereby charging him with DUI third offense, a Class 6 felony. The plain language of S.D. Codified Laws 23A-4-3 entitles a defendant to a preliminary hearing if he is charged with an offense "punishable as a felony." The Supreme Court reversed Defendant's conviction and remanded the case for further proceedings, holding that because Defendant faced a potential felony conviction he was entitled to a preliminary hearing. View "State v. Rus" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the circuit court entering judgment in favor of Thomas Wright on his claims for negligence, breach of contract, and deceit, holding that the circuit court erred in its damages award.Curtis Temple expressed interest in purchasing Wright's airplane and took the plane to his ranch, where it was damaged in a crash. When Wright's attempts to obtain compensation from Temple were unsuccessful, he brought suit. Temple also filed a third-party complaint against Ken Merrill, Temple's flight instructor, for negligence and contribution in the event Temple were to be found liable for damages. The jury found Temple liable to Wright on the claims of negligence, breach of contract, and deceit, and awarded damages. The jury also found Temple liable to Merrill but did not award damages to Merrill. The Supreme Court reversed in part and remanded the case for a new trial on the limited issue of damages, holding (1) there was sufficient evidence to support the finding that Temple breached a contract between Temple and Wright; (2) there was sufficient evidence to support the finding that Temple was negligent; and (3) the circuit court erred in instructing the jury on damages and in determining the total award. View "Wright v. Temple" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated assault and one count of simple assault against a law enforcement officer, holding that there was no error.On appeal, Defendant claimed, among other things, that her conviction of aggravated assault was unlawful because the gun she was holding at the time of the incident giving rise to her convictions was inoperable. The Supreme Court affirmed, holding that the circuit court (1) did not err by denying Defendant's motion to suppress evidence of Defendant's conduct giving rise to the simple assault charge; (2) did not err, under the circumstances, by not instructing the jury on the definition of a firearm and by prohibiting Defendant's argument regarding firearm operability; and (3) did not err by denying Defendant's motion for judgment of acquittal. View "State v. Schumacher" on Justia Law