Justia South Dakota Supreme Court Opinion Summaries

In this guardianship and conservatorship action, the Supreme Court affirmed the judgment of the circuit court granting the conservator's motion for approval of a settlement agreement reached in a separate civil action brought by the conservator against the protected person's son and daughter-in-law, holding that the circuit court did not err.Three of the protected person's other children objected to the conservator's motion for approval of the settlement agreement, requesting that they be allowed to present live testimony at the hearing on the motion. The circuit court denied the request and, after a hearing, granted the conservator's motion for approval of the settlement. The Supreme Court affirmed, holding that the circuit court did not err in denying an evidentiary hearing and in approving the settlement agreement. View "In re Guardianship & Conservatorship of Adam" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the circuit court granting summary judgment in favor of Defendants in this wrongful death suit, holding that the circuit court properly dismissed Plaintiffs' negligence claims but erred in dismissing Plaintiffs' strict liability claim.Chalan Hedman and Troy Hattum died after and explosion and fire at the Hattum Family Farms. Chalan's estate brought a wrongful death suit against Hattum Family Farms and individual members of the Hattum family, alleging claims for strict liability and negligence and seeking compensatory and punitive damages. The circuit court granted summary judgment for the Hattums on the Estate's claims. The Supreme Court reversed in part, holding that the circuit court erred by granting summary judgment on the strict liability claim because genuine issues of material fact existed precluding dismissal. View "Sheard v. Hattum" on Justia Law

The Supreme Court affirmed the order of the circuit court granting summary judgment to Defendants, the City of Pierre and the Pierre Volunteer Fire Department (PVFD), in this personal injury action, holding that the trial court correctly determined that the City and the PVFD were not vicariously liable under the circumstances of this case.Gerrit Tronvold, an on-call volunteer member of the PVFD, collided with Plaintiffs' motorcycle while his was traveling to a routine PVFD meeting. The trial court determined that the City and the PVFD were not vicariously liable for Tronvold's actions under the doctrine of respondeat superior and that the defendants were shielded from liability by governmental immunity. The Supreme Court affirmed, holding that the trial court correctly determined that Tronvold was not acting within the scope of his employment or agency, precluding liability under the doctrine of respondeat superior. View "Jurgens v. Tronvold" on Justia Law

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