Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's sentence of eighty years imprisonment with forty years suspended for first-degree manslaughter, holding that the sentence was not grossly disproportionate to the offense and did not violate the Eighth Amendment.Specifically, the Supreme Court held (1) Defendant's sentence was not grossly disproportionate to the offense of first-degree manslaughter under the Eighth Amendment; (2) at sentencing, the circuit court properly examined the events surrounding the offense, Defendant's character and history, and Defendant's rehabilitation prospects; and (3) the circuit court did not abuse its discretion in crafting the sentence. View "State v. Holler" on Justia Law

The Supreme Court affirmed the judgment of the circuit court determining that a limited private easement granted Thomas Estes the right of access across Lot 2R within the Estes Subdivision solely to repair or install water lines and that a prescriptive easement did not exist in favor of Estes for the use of a road (Easement Road) that crossed Lot 2R, holding that the circuit court did not err.Estes owned Lots 3 and 4R2 in the subdivision, and Kathrine owned Lot 2R. After hostiles developed concerning Estes' use of the Easement Road, the parties filed multiple claims against one another. After several of the claims were settled or resolved on summary judgment the circuit court resolved the remaining claims during a bench trial. Estes appealed. The Supreme Court affirmed, holding (1) the circuit court did not err when it limited the private easement granting a right of access across Lot 2R solely for the repair or installation of water lines; and (2) the circuit court did not err in determining that the evidence did not satisfy the elements for a prescriptive easement. View "Helleberg v. Estes" on Justia Law

The Supreme Court affirmed the decision of the circuit court affirming the assessed value of Appellants' agricultural land by the Meade County Commission sitting as a board of equalization (the Board), holding that the circuit court did not err.Before the Board, Appellants argued that the director of equalization incorrectly applied statutory provisions to determine their land's production value. The Board further adjusted the assessment from an average of $519 per acre down to an average of $512 per acre. Appellants appealed the Board's decision to circuit court. After a trial de novo, the circuit court affirmed the Board's tax assessment of the property. The Supreme Court affirmed, holding that the circuit court did not err when it determined that (1) the Board complied with the statutory provisions for evaluating agricultural land in their assessment of Appellants' property; and (2) the Board's tax assessment of the property did not violate provisions of the South Dakota Constitution that require uniform taxation at no more than its actual value. View "Trask v. Meade County Commission" on Justia Law

The Supreme Court affirmed the judgment of the circuit court in favor of Children's Care Hospital and School (CCHS) as to Benjamin Graff's complaint alleging that CCHS was negligent and inflicted emotional distress by using physical restraints on him when he received services at CCHS, holding that the circuit court did not err in excluding various Department of Health surveys and by taxing partial disbursements against Graff's parents.Graff, who was in the moderately to severely impaired range of intellectual ability, was receiving services through CCHS when, as a teenager, he began acting out aggressively. CCHS employees used physical restraints on him. Through his parents acting as guardians ad litem, Graff commenced this action alleging, among other things, that CCHS was negligent in its use of physical restraints on him. A jury returned a verdict in favor of CCHS on all of Graff's claims. The circuit court taxed partial disbursements against Graff's parents. The Supreme Court affirmed, holding (1) the circuit court's exclusion of the Department of Health surveys did not prejudice Graff; and (2) the circuit court did not abuse its discretion when it apportioned disbursements against Graff's parents. View "Graff v. Children’s Care Hospital & School" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court denying Karen Dunham's petition for writ of certiorari challenging the decision of the Lake County Board of Adjustment (Board) approving Hodne Homes, LLC's requests for a variance and conditional use permit (CUP), holding that the Board exceeded its authority in granting the variance but did not exceed its legal authority when it approved the CUP.Hodne Homes purchased a Lake County lot to build a facility to store and display boats. Hodne Homes sought the variance and CUP because the proposed facility exceeded the size and setback restrictions for the lot under the Lake County Zoning Ordinance. Dunham, an adjoining landowner, objected, but the Board granted both requests. The court of appeals denied Dunham's petition for writ of certiorari challenging the Board's decision. The Supreme Court reversed in part, holding (1) the Board exceeded its legal authority under the ordinance when it approved the variance; and (2) the Board did not exceed its authority under the ordinance when it approved the CUP, the Board's decision did not violate Dunham's due process rights, and the Board committed no procedural errors in its approval of the CUP. View "Dunham v. Lake County Commission" on Justia Law

The Supreme Court dismissed for lack of appellate jurisdiction Appellants' appeal from the circuit court's order granting summary judgment dismissing some but not resolving all of the parties' claims, holding that the circuit court's summary judgment order was indisputably not final.The circuit court's order granting summary judgment did not resolve all of the parties' claims, and it was not certified as a final decision prior to Appellants' appeal. The Supreme Court dismissed the appeal without reaching the merits of the appeal, holding that because the circuit court resolved only part of the case and the summary judgment order did not cite S.D. Codified Laws 15-6-54(b) (Rule 54(b)), did not designate the order as final, and was not accompanied by a reasoned statement supporting a Rule 54(b) certification, this Court lacked appellate jurisdiction. View "Huls v. Meyer" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's motion for judgment of acquittal after a jury found Defendant guilty of aggravated assault, holding that there was sufficient evidence to support the verdict.After a trial, the jury found Defendant guilty of aggravated assault. Defendant moved for judgment notwithstanding the verdict, which the circuit court denied. The court sentenced Defendant to a seven-year term of imprisonment, suspended in favor of probation for three years. Defendant appealed the denial of his motion for judgment of acquittal. The Supreme Court affirmed, holding that the State proved every element of aggravated assault, and a rational trier of fact could have found Defendant guilty beyond a reasonable doubt. View "State v. Ware" on Justia Law

The Supreme Court affirmed the judgment of the circuit court concluding that coverage did not exist under an automobile insurance policy issued to Shelby Olsons' parents or an automobile policy issued to the shooter for injuries sustained by Shelby when she was struck by a bullet while riding in the backseat of her parents' vehicle, holding that the circuit court did not err.Shelby was struck by a bullet when the driver of another vehicle fired a handgun at the Olsons' vehicle. At issue was whether coverage for Shelby's injuries existed under the automobile policy issued to her parents or under the automobile policy issued to the shooter. The circuit court concluded that coverage did not exist under either policy because the injuries did not arise out of the use of a vehicle and, alternatively, were not caused by an accident. The Supreme Court affirmed, holding that the circuit court did not err in granting summary judgment in favor of the insurance companies. View "Olson v. Slattery" on Justia Law

In this dispute over the sale proceeds from an auction of cattle the Supreme Court affirmed in part and reversed in part the entry of partial summary judgment on Plaintiff's claim for the sale proceeds, holding that Defendant had a right to pursue his disputed claim for an additional $12,500.Pursuant to the terms of a sales agreement Plaintiff purchased cows and calves from Defendant. The agreement required Plaintiff to pay for the cattle in installments, with Defendant retaining a security interest in the cattle. After Plaintiff sold the remaining cows purchased from Defendant at auction Plaintiff calculated a payoff to Defendant to satisfy the balance of the agreement, with a remaining balance paid to Plaintiff. When Defendant refused to allow any of the sale proceeds to be released from the auction barn Plaintiff brought this action. The circuit court granted Plaintiff's motion for partial summary judgment on its claim for the sale proceeds and entered judgment against Defendant for $185,718. The Supreme Court held (1) Defendant's appeal from the order denying his motion for change of venue is dismissed for lack of jurisdiction; and (2) disputed facts existed concerning Defendant's claim that he was owed an additional $12,500 under the sales agreement. View "Stromberger Farms, Inc. v. Johnson" on Justia Law

The Supreme Court affirmed the circuit court's decision invalidating the will and codicil of Dora Lee Gaaskjolen on the basis of undue influence, holding that the circuit court's determination of undue influence was not clearly erroneous.Dora Lee and her husband, Marlin, executed reciprocal wills giving their property to one another upon death, and their daughters, Audrey and Vicki, were named as equal, alternate beneficiaries. After Marlin died, Dora Lee executed a new will and, later, another will and codicil that disinherited Vicki and left her entire estate to Audrey. After Dora Lee died, Vicki challenged the will and codicil, claiming that Dora Lee lacked testamentary capacity and that Audrey had unduly influence Dora Lee. The circuit court concluded that Dora Lee had testamentary capacity but that Dora Lee's last will and codicil were the result of undue influence by Audrey. The Supreme Court affirmed, holding that the circuit court did not err in finding the last will and the codicil invalid because of Audrey's undue influence. View "In re Estate Of Gaaskjolen" on Justia Law