Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the circuit court dismissing this suit against Marty Indian School (MIS), a legal entity of the Yankton Sioux Tribe, for a lack of subject matter jurisdiction based on federal preemption, holding that the circuit court lacked subject matter jurisdiction to hear Plaintiff's claims against MIS.Plaintiff, the former high school principal at MIS, sued MIS and other involved parties after he was terminated. Plaintiff alleged claims for breach of contract, breach of settlement agreement, wrongful termination, libel, and slander, and requested punitive damages. The circuit court dismissed the complaint on the grounds of tribal sovereign immunity, immunity of tribal officials and employees, infringement of tribal sovereignty, and federal preemption. The Supreme Court affirmed the dismissal solely on a lack of subject matter jurisdiction based on federal preemption, holding that state court action in this dispute was preempted by federal law. View "Stathis v. Marty Indian School" on Justia Law

The Supreme Court reversed the order of the circuit court granting the motion to dismiss filed by Waste Connections of South Dakota, Inc. on Kimberlynn Cameron's complaint, holding that Cameron properly initiated suit against Waste Connections prior to the expiration of the statute of limitations, and therefore, the circuit court erred when it dismissed the suit.Cameron brought a personal injury suit against Jason Osler after she was injured in a car accident. Thereafter, Cameron filed an amended complaint adding a claim for vicarious liability and naming Waste Connections, Osler's employer, as a defendant. Cameron, however, failed timely to serve Osler, and he was dismissed from the suit. In its motion to dismiss Waste Connections argued that Cameron's failure to timely serve Osler precluded suit against Waste Connections. The circuit court granted the motion to dismiss. The Supreme Court reversed, holding that the dismissal of Osler did not preclude suit against the employer for vicarious liability. View "Cameron v. Osler" on Justia Law

In this declaratory relief proceeding, the Supreme Court affirmed the circuit court's denial of State Farm's motion for summary judgment and entered a judgment in favor of LeRoy James on his complaint alleging that State Farm had no right to reimbursement or subrogation for paying James's medical expenses under his policy, holding that State Farm had no contractual right to reimbursement for the $5,000 paid to James for medical expenses under the policy.State Farm insured both James and Melissa Rivers, who rear-ended James and caused him personal injury. State Farm paid a portion of James's medical expenses under his policy and then, acting on behalf of Rivers, settled with James. Once James released Rivers from liability, State Farm demanded that James use his settlement proceeds to reimburse State Farm for paying his medical expenses. James then brought this action. The circuit court entered a judgment in favor of James. The Supreme Court affirmed, holding that the text of the reimbursement provision of the policy was ambiguous, and therefore, State Farm had no contractual right to reimbursement from James. View "James v. State Farm Mutual Automobile Insurance Co." on Justia Law

In this negligence case, the Supreme Court affirmed the judgment of the circuit court finding that Defendant was not negligent, holding that Plaintiff's claims of error, many of which related to the jury instructions, were unavailing.Plaintiff sought Defendant, a restaurant, for negligence, alleging that Defendant failed to take reasonable measures to keep its parking lot safe by removing snow and ice. After the close of the evidence, the trial court struck Defendant's defense of assumption of risk but determined that Defendant had presented sufficient evidence to submit the issue of contributory negligence to the jury. The jury entered a verdict finding Defendant not negligent. The Supreme Court affirmed, holding (1) there was no error in the jury instructions, and the court provided the jury a full and accurate statement of the applicable law and legal principles; and (2) because the jury found Defendant not negligent, this Court need not address Plaintiff's remaining issues related to the defense of contributory negligence and her request for an instruction on dormant pre-existing health conditions. View "Tammen v. K & K Management Services, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction of simple assault and kidnapping, holding that the trial court did not err in the proceedings below and that Defendant's sentence was not unconstitutional under the Eighth Amendment.Specifically, the Court held (1) the circuit court did not err when it denied Defendant's motion for a mistrial for an alleged Brady violation; (2) the circuit court did not abuse its discretion when it denied Defendant's motion for a mistrial; (3) Defendant was not denied a fair trial due to cumulative errors; and (4) Defendant's sentence was not grossly disproportionate or excessive. View "State v. Delehoy" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dividing marital property, awarding spousal support and attorney fees to Kathleen Taylor in the underlying action for divorce, and levying contempt orders against Bruce Taylor in the proceedings, holding that the spousal support awards and the award of attorney fees must be reversed and remanded.Specifically, the Court held (1) the circuit court did not abuse its discretion in dividing the marital assets; (2) the court abused its discretion by failing to reconsider the interim support order and by maintaining the order until the court rendered its decision seven months after trial; (3) the circuit court did not err in finding Bruce in contempt of court; and (4) the circuit court's award of attorney fees to Kathleen was an abuse of discretion because the award was not based upon an itemized statement of fees provided by Kathleen. View "Taylor v. Taylor" on Justia Law

The Supreme Court affirmed the decision of the circuit court affirming the magistrate judge's denial of Defendant's motion to suppress evidence obtained during a vehicle stop, holding the magistrate judge did not err by concluding that the stop was justified under the community caretaker exception.Defendant was convicted in magistrate court of driving under the influence. Defendant appealed the denial of his motion to suppress all evidence and statements obtained during the traffic stop, arguing that the police officer lacked reasonable suspicion of criminal activity. The Supreme Court affirmed, holding that the officer was acting in his community caretaking role when he stopped Defendant's vehicle in the parking lot, and the officer provided specific and articulable facts supporting his decision to stop Defendant's vehicle. View "State v. Short Bull" on Justia Law

The Supreme Court affirmed the decision of the circuit court affirming Meade County's denial of Hunt Companies, Inc.'s request for an abatement and refund of taxes overpaid, holding that, although the County overvalued Hunt's leasehold interest in a housing development, the circuit court did not err by denying Hunt's application for abatement and refund under S.D. Codified Laws 10-18-1.Hunt built the housing development at issue on land leased from the United States government. Hunt paid taxes assessed by the County on the property for 2011 through 2013. Hunt successfully challenged the County's valuations in circuit court, but the County denied Hunt's request for an abatement and refund. The Supreme Court affirmed, holding that the County was not required to grant Hunt's application for abatement and refund of taxes overpaid for the tax years at issue where Hunt chose not to use the pay-and-protest provisions of S.D. Codified Laws 10-27-2. View "In re Tax Refund Of Hunt Companies, Inc." on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting Father's motion to modify custody to award him primary physical custody of the parties' minor children, holding that the record supported the court's decision to award primary physical and legal custody to Father.In 2014, the circuit court entered a judgment and decree of divorce based on irreconcilable differences. The judgment and decree incorporated the parties' stipulation providing that Mother would have primary physical custody of the parties' children. In 2016, Father filed a motion for primary physical custody of the children. The circuit court held that the best interest of the children would be served by modifying the judgment and decree of divorce to award primary physical and legal custody of the children to Father. The Supreme Court affirmed, holding that the circuit court (1) had subject matter jurisdiction to determine custody; (2) did not err in concluding that Father did not have a history of domestic abuse; (3) did not err in determining that Father overcame the presumption under S.D. Codified Laws 25-4-45.5; and (4) did not abuse its discretion in awarding primary physical custody to Father. View "Shelstad v. Shelstad" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated assault by physical menace, holding that no error requiring reversal occurred in the proceedings below.A jury found Defendant guilty of the aggravated assault of his wife and his wife's sister. The Supreme Court affirmed the convictions, holding (1) Defendant was not prejudiced by the circuit court's decision in admitting a police officer's opinion on the nature of Defendant's wife's wounds, but the error was not prejudicial; (2) the evidence was sufficient to support both counts of aggravated assault by physical menace; and (3) the trial court erred in including a notation that the aggravated assault of Defendant's wife constituted domestic abuse when the jury made no such finding, but the remedy is to remand for entry of an amended judgment without the notation. View "State v. Scott" on Justia Law