Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's convictions and sentences for kidnapping, rape, aggravated assault, and commission of a felony with a firearm, holding that there was no error or abuse of discretion.Specifically, the Supreme Court held (1) the circuit court did not abuse its discretion when it granted the State's motion in limine regarding erotic asphyxiation; (2) Defendant's prosecutorial misconduct claims were unfounded; (3) the circuit court did not err in denying Defendant's motion for judgment of acquittal on all counts on which Defendant was convicted; and (4) Defendant's seventy-five-year sentence was not grossly disproportionate in violation of the Eighth Amendment. View "State v. Seidel" on Justia Law

The Supreme Court affirmed the judgment of the circuit court concluding that Plaintiffs had standing to bring this declaratory judgment action challenging ad valorem property taxes that Day County assessed against them and upholding the disputed taxes, holding that the circuit court did not err.Plaintiffs were the Pickerel Lake Outlet Association, a South Dakota domestic non-profit corporation, and forty non-Indian owners of permanent improvements around Pickerel Lake. Plaintiffs claimed that federal law preempted taxation because their structures were on land held in trust for the Sisseton-Wahpeton Oyate or its members. The State defended the County's authority to levy the taxes, arguing that preemption did not apply and challenging Plaintiffs' standing to sue. The circuit court concluded that Plaintiffs had standing and upheld the County's authority to assess the taxes. The Supreme Court affirmed, holding (1) Plaintiffs satisfied all the prerequisites for standing; and (2) the County was neither explicitly nor implicitly preempted by the provisions of 25 U.S.C. 5108 from assessing ad valorem taxes against Plaintiffs. View "Pickerel Lake Outlet Ass'n v. Day County" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated assault and two counts of simple assault for attacking his former significant other, Rosa Sosa, holding that the circuit court did not err in excluding evidence of Sosa's drug use and that Defendant was not entitled to relief on his double jeopardy claims.Specifically, the Supreme Court held (1) the circuit court did not err in granting the State's motion in limine to exclude evidence of the victim's methamphetamine use; and (2) Defendant's convictions for multiple counts of assault did not subject him to double jeopardy. View "State v. Babcock" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and other offenses, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Court held (1) if the circuit court erred in denying Defendant's motion to suppress his statements to law enforcement, the error was harmless because the statements were cumulative to other evidence received; (2) the circuit court did not abuse its discretion or commit prejudicial error by refusing to declare certain witnesses adverse; (3) Defendant's Sixth Amendment rights were not violated; and (4) the evidence presented at trial was sufficient to support Defendant's guilty verdict on all counts. View "State v. Quinones Rodriguez" on Justia Law

In this case brought by a patient who sued her doctor for lack of informed consent, the Supreme Court reversed the decision of the circuit court granting in part Plaintiff's motion to compel the production of medical records of Defendant's non-party patients, holding that the circuit court erred.Plaintiff underwent an anterior spinal surgery with Defendant, a general surgeon, to relieve lower back pain. After Defendant performed a vertical incision rather than Plaintiff's requested horizontal incision Plaintiff brought this action alleging that Defendant performed the vertical incision without Plaintiff's informed consent. At issue was Plaintiff's motion to compel certain non-party patients' medical records. The circuit court granted the motion to compel in part, limiting the scope of the discoverable records. The Supreme Court reversed the order, holding that the records Plaintiff requested were irrelevant and therefore not discoverable. View "Ferguson v. Thaemert" on Justia Law

In this insurance dispute arising from an employee's death, the Supreme Court remanded the determination that the employer's insurer providing underinsured motorist coverage and workers' compensation insurance was entitled to a lien on a portion of settlement proceeds received by the estate, holding that, given a lack of factual findings, there was no way to evaluate whether the court clearly erred in its assessment of the various factors impacting an equitable allocation.Charles Luze died in a work-related accident. His employer paid his wife, Jeanette Luze, workers' compensation benefits. Jeanette, as the representative of Charles's estate, then brought suit against the negligent driver and settled the claim. The estate also settled a claim against the New FB's insurer providing underinsured motorist coverage, Zurich American Insurance Company, which was also New FB's workers' compensation carrier. The circuit court determined that Zurich was entitled to a statutory workers' compensation lien on fifty percent of the settlement proceeds received by the estate and was able to subrogate against its own settlement payment of underinsured benefits. The Supreme Court remanded in part, holding (1) this Court was unable meaningfully to review the circuit court's allocation determination; and (2) the circuit court properly allowed Zurich to subrogate against the amount it paid in underinsured motorist benefits. View "Luze v. New FB Co." on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of vehicular homicide, one count of vehicular battery, and driving while under the influence of alcohol, holding that the circuit court did not commit error in the proceedings below.On appeal, Defendant argued that the circuit court erred in denying his motion to suppress a warrantless blood draw and asked the Supreme Court to review his ineffective assistance of counsel claims on direct appeal. The Supreme Court affirmed, holding (1) the circuit court did not err when it denied Defendant's motion to suppress his warrantless blood draw; and (2) Defendant's ineffective assistance of counsel claim is not cognizable on direct appeal. View "State v. Vortherms" on Justia Law

The Supreme Court affirmed Defendant's conviction of simple assault on a law enforcement officer, holding that Defendant was not entitled to relief on any of her assignments of error.Specifically, the Supreme Court held (1) the circuit court did not err when it denied Defendant's motion for a judgment of acquittal; (2) the circuit court did not err by instructing the jury on facts not entered into the record; and (3) the circuit court did not violate Defendant's constitutional right of confrontation under the Sixth Amendment by admitting a certified conviction from Codington County in the habitual offender trial. View "State v. McReynolds" on Justia Law

The Supreme Court affirmed Defendant's conviction of eight counts of first-degree child rape and four counts of sexual contact with a child, holding that no prejudicial error occurred in the proceedings below.Specifically, the Supreme Court held (1) the circuit court did not err in denying Defendant's motion for a bill of particulars and his motion to quash the indictment; (2) the circuit court did not abuse its discretion in admitting internet searches and images on Defendant's cell phones and tablet; (3) the circuit court did not abuse its discretion in admitting a witness's hearsay statements; (4) the circuit court did not err in failing to enter a judgment of acquittal on any of the charges; and (5) Defendant's sentences were not cruel and unusual in violation of the Eighth Amendment. View "State v. Snodgrass" on Justia Law

The Supreme Court affirmed the judgment of the circuit court entering judgment in favor of Yankton County on Sacred Heart Health Service Inc.'s (Hospital) declaratory judgment against the County, holding that circuit court did not err in holding S.D. Codified Laws chapter 28-13 is the proper mechanism for the Hospital to obtain reimbursement from the County for medical costs associated with the twenty-three patients in the involuntary commitment process.The Hospital brought a declaratory judgment action against the County seeking a declaration as to the County's liability and reimbursement for charges for the medical care and treatment of patients subject to an emergency hold under S.D. Codified Laws chapter 27A-10. The circuit court first entered a memorandum decision in favor of the Hospital, but after granting the County's motion to reconsider issued a second memorandum decision and corresponding judgment in favor of the County. The Supreme Court affirmed, holding (1) the circuit court did not err in granting the County's motion for summary judgment; (2) the Hospital did not have a claim in quantum merit for reimbursement from the County; and (3) the circuit court did not err in granting the County's motion to reconsider. View "Sacred Heart Health Services v. Yankton County" on Justia Law