Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of hit and run involving an injury, holding that the State was not required to prove that Defendant had knowledge of an accident-related injury.Defendant pled guilty to driving under the influence, second offense, and, after a bench trial, was convicted of felony hit and run. Defendant appealed, arguing that the circuit court erred when it found that S.D. Codified Laws 32-34-5 does not require knowledge of the injury as an essential element. The Supreme Court affirmed, holding that, under the circumstances, the circuit court did not err in determining that knowledge of the injury was not an essential element of a felony hit-and-run offense and denying Defendant's motion for judgment of acquittal. View "State v. Nekolite" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder, holding that the circuit court did not err in its evidentiary rulings and that there was sufficient evidence to sustain the conviction.On appeal, Defendant argued that the circuit court abused its discretion by admitting other acts testimony from three witnesses over Defendant's objection and erred in denying his motion for judgment of acquittal. The Supreme Court affirmed, holding (1) Defendant failed to establish that the admission of the challenged testimony was unfairly prejudicial or that it affected the jury's verdict; and (2) because a rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt the evidence was sufficient to support the conviction of second-degree murder. View "State v. Harruff" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the judgment of the circuit court entering summary judgment in favor of Attorney in this legal malpractice action and dismissing the action, holding that the circuit court did not abuse its discretion in allowing Attorney's amendment to her answer but erred in determining that Plaintiff's claims were untimely under S.D. Codified Laws 15-2-14.2.Plaintiff brought this action against Attorney and Law Firm arising from Attorney's representation of Plaintiff on a claim for personal injuries. The circuit court determined that the action was time barred by section 15-2-14.2 and dismissed the action. The Supreme Court reversed in part, holding that the circuit court (1) did not abuse its discretion by permitting Attorney to amend her answer to allege section 15-2-14.2 as an affirmative defense; but (2) erred in determining that this action was barred by the repose period under section 15-2-14.2. View "Robinson-Podoll v. Harmelink, Fox, & Ravnsborg Law Office" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's motion for judgment of acquittal and refusing Defendant's requested jury instructions pertaining to the language of "directly" in S.D. Codified Laws 22-22-45 and specific intent, holding that there was no reversible error in this case.After a jury trial, Defendant, an inmate, was found guilty of one count of threatening to commit a sexual offense. The conviction stemmed from Defendant's act of writing and mailing two letters containing threats to rape and murder a mental health therapist at the prison where Defendant was incarcerated. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the conviction; and (2) the circuit court's instructions to the jury pertaining to the language of "directly" in S.D. Codified Laws 22-22-45 and specific intent did not prejudice Defendant. View "State v. Armstrong" on Justia Law

In this case concerning the will of Russell Tank naming his neighbor Jason Bender as his sole heir and disinheriting his four adult children (Children) the Supreme Court affirmed in part and reversed in part the decision of the circuit court dismissing Children's petition challenging the will, holding that summary judgment was improperly granted on one of the children's claims of undue influence.Children filed a petition challenging the will naming Bender as Russell's sole heir on the grounds of lack of testamentary capacity, insane delusions, and undue influence. The circuit court granted summary judgment in favor of Bender. The Supreme Court reversed in part, holding that the circuit court (1) did not err in concluding that there were no genuine issues of material fact showing Russell lacked testamentary capacity to execute the will; (2) did not err in determining that there were no genuine issues of material fact showing Russell suffered from an insane delusion affecting the terms of his will; and (3) erred in determining that that there were no material issues of fact on one of the children's claim that the will was the product of undue influence but did not err in concluding that there was no evidence to support the remaining children's claim of undue influence. View "In re Estate Of Tank" on Justia Law

The Supreme Court affirmed the decision of the Lake County Board of Commissioners, sitting as the Lake County Drainage Board (Board), approving the application for permits filed by Steven Carmody and Edward Becker to install drain tile on their respective properties in Lake County, holding that the circuit court did not err when it affirmed the Board's decision to issue the drainage permits.James Carmody objected to both permits and appealed the Board's approval of the permits to the circuit court. The circuit court applied the abuse of discretion standard of review and affirmed the Board's approval of the drainage permits. The Supreme Court affirmed, holding that the circuit court (1) applied the correct standard of review and burden of proof to Carmody's appeal of the drainage permits; and (2) did not abuse its discretion when it affirmed the Board's decision to issue the drainage permits. View "Carmody v. Lake County Board Of Commissioners" on Justia Law

The Supreme Court affirmed the order of the circuit court affirming the decision of the Department of Labor determining that Appellant's knee surgery and related treatment were not compensable, holding that the Department did not err when it concluded that Appellant's work-related injury, in combination with his preexisting condition, did not remain a major contributing cause of his disability, impairment, or need for treatment.Appellant injured his left knee while working for Appellee. Appellee denied liability for Appellant's total knee replacement surgery and post-operative treatment. The Department found the work-related injury neither contributed independently nor was a major contributing cause of Appellant's need for surgery. The circuit court affirmed. The Supreme Court affirmed, holding that Appellant failed to prove causation under either S.D. Codified Laws 62-1-1(7)(b) or S.D. Codified Laws 62-1-1(7)(c). View "Armstrong v. Longview Farms, LLP" on Justia Law

The Supreme Court reversed the denial of Defendant's motion to suppress evidence seized from his hotel room pursuant to a search warrant, holding that the officer who previously detained Defendant's vehicle and gathered information eventually contained in the search warrant affidavit did not have reasonable suspicion or probable cause to stop Defendant's vehicle and that all evidence obtained after the stop must be suppressed under the exclusionary rule.Defendant was stopped because the officer observed a brake light emit a white light. A consent search of the vehicle did not produce evidence of unlawful drugs, but the officer later found a foil ball in the vehicle, which tested positive for methamphetamine. Thereafter, police officers seized evidence from Defendant's hotel room pursuant to a search warrant. Defendant filed a motion to suppress, arguing that the officer did not have reasonable suspicion to stop his vehicle because it had two properly working brake lights. The circuit court denied the motion. The Supreme Court reversed, holding (1) the officer did not have reasonable suspicion or probable cause to stop Defendant's vehicle; and (2) once the information derived from the unlawful traffic stop was excluded from the search warrant affidavit, it lacked a substantial basis upon which probable cause could be found. View "State v. Tenold" on Justia Law

The Supreme Court affirmed the circuit court's judgment denying Appellant's second application for writ of habeas corpus, holding that Defendant did not meet his burden to show deficient performance and prejudice on his ineffective assistance of counsel claims and that Appellant's remaining claims were not reviewable or meritorious habeas claims.In his habeas corpus application, Appellant claimed that his original guilty pleas were not made voluntarily and intelligently, that the court upon his resentencing abused its discretion when it denied his motion to introduce evidence of the State's alleged inconsistent previous arguments, and that he received ineffective assistance of counsel at his initial change of plea hearing and at his jury resentencing. The circuit court denied relief. The Supreme Court affirmed, holding (1) Appellant cannot challenge his guilty plea or alleged inconsistent arguments on the merits under the procedural framework of a habeas action; and (2) Appellant did not meet the Strickland standard to establish ineffective assistance of counsel. View "Piper v. Young" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decision of the circuit court dismissing an application for a writ of prohibition, sua sponte, for lack of subject matter jurisdiction, holding that the circuit court erred by dismissing the alternative application for writ of certiorari.Triple K Land, LLC successfully applied to the Hanson County Board of adjustment for a conditional use permit to construct a pig nursery facility. Loren Huber and Amy Nolan-Huber (the Hubers), adjacent property owners, applied for a writ of prohibition, alternatively designating the application as a verified petition setting forth the illegality of the Board's decision. During a hearing, the circuit court granted Triple K's oral motion to intervene. The court then dismissed the application for lack of subject matter jurisdiction. The Supreme Court reversed in part, holding (1) insofar as the circuit court dismissed the claim for writ of prohibition, it did not err; (2) the Hubers complied with the requirements of S.D. Codified Laws 11-2-61, and the circuit court had subject matter jurisdiction to hear the matter by writ of certiorari; and (3) the circuit court did not abuse its discretion in granting Triple K's motion to intervene. View "Huber v. Hanson County Planning Commission" on Justia Law