Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court affirming the decision of the Department of Labor to award benefits to James Bonebright's widow, Stephanie, after Bonebright died from injuries he sustained in a work-related accident, holding that the workers' compensation claim was not precluded by willful misconduct.Bonebright's employer, the City of Miller, and the City's workers' compensation provider denied workers' compensation liability on the ground that Bonebright had engaged in willful misconduct. Stephanie petitioned the Department for medical and funeral expenses along with indemnity benefits as a surviving spouse. The Department awarded Stephanie benefits, concluding that although Bonebright had engaged in willful misconduct, the City had not established that Bonebright's failure to follow safety precautions was a proximate cause of his injury and death. The circuit court reversed the Department's willful misconduct finding. The Supreme Court affirmed, holding that Stephanie's claim was not precluded by willful misconduct because the City did not demonstrate bona fide enforcement of its safety rules. View "Bonebright v. City Of Miller" on Justia Law

The Supreme Court affirmed the decision of the circuit court determining that Insurer's decision to deny coverage for a single-vehicle accident was not in violation of its duty, holding that the court did not err in concluding that the insurance policy did not provide coverage for Defendant's injuries.Appellant suffered serious injuries when a van in which he was a passenger rolled over in a single-vehicle accident. Appellant brought an action against the driver for personal injuries. The driver had purchased a motor vehicle insurance policy from Insurer. Relying upon policy provisions excluding coverage for any vehicle being used to carry people for a fee, Insurer denied coverage and refused to defend the driver. Insurer then brought this declaration action against Appellant and the driver to determine coverage. The circuit court determined that Insurer had no contractual obligation to defend the driver or provide indemnity for the accident. The Supreme Court affirmed, holding the circuit court did not err in concluding that Insurer's policy exclusions were applicable and denying coverage for the accident. View "Western Agricultural Insurance Co. v. Arbab-Azzein" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing as untimely Appellant's appeal of an order of the Board of Pardons and Paroles revoking Appellant's parole, holding that the circuit court did not err.Thirty-four days after the Board entered an amended order revoking Appellant's parole the clerk of court received and filed Appellant's pro se notice of appeal. The Board filed a motion to dismiss the appeal for lack of jurisdiction, claiming it was untimely. The circuit court dismissed the appeal for lack of jurisdiction. The Supreme Court affirmed, holding that the circuit court (1) did not err when it dismissed as untimely Appellant's appeal of the Board's decision revoking Appellant's parole; and (2) did not abuse its discretion by denying Appellant's request for a standby attorney at the hearing on the motion to dismiss his appeal. View "Abdulrazzak v. South Dakota Board of Pardons & Paroles" on Justia Law

The Supreme Court affirmed Defendants' convictions of first-degree manslaughter and sentences of life imprisonment, holding that the circuit court did not err or abuse its discretion in either case.Daniel Ceplecha and his son, Rangler Ceplecha, each pled guilty to first-degree manslaughter pursuant to a plea agreement. Prior to sentencing, Defendants filed motions to withdraw their pleas, asserting that they acted in self-defense. The circuit court denied the motions. Thereafter, the circuit court sentenced each defendant to life in prison. The Supreme Court affirmed, that the circuit court (1) did not abuse its discretion in denying Rangler's motion for new counsel because he failed to establish a fair and just reason in support of his request; (2) did not abuse its discretion by denying Defendants' motions to withdraw their guilty pleas; and (3) did not abuse its discretion or violate the Eighth Amendment by imposing life sentences. View "State v. Ceplecha" on Justia Law

The Supreme Court reversed the circuit court's dismissal of Plaintiff's deceit claim and affirmed the circuit court's rulings as to Plaintiff's breach of contract, negligent misrepresentation and fraud claims and as to Defendants' counterclaim seeking damages under two three-year lease agreements allowing Plaintiff to rent Defendants' ranch, holding that the circuit court erred in concluding that Defendants fraudulently induced Plaintiff to enter into one of the leases.Following disputes between the parties, Defendants refused Plaintiff's lease payments for the second year. Plaintiff filed suit, and Defendants counterclaimed. The trial court found one lease valid and binding and the other lease valid but voidable. A jury awarded damages to both parties. The Supreme Court reversed in part and otherwise affirmed, holding (1) the circuit court did not abuse its discretion in its evidentiary rulings and in its jury instructions; (2) the circuit court did not err when it found the second lease voidable instead of void; and (3) the circuit court erred when it granted Defendants' motion for summary judgment on Plaintiff's claim that Defendants fraudulently induced him to enter into the second lease. The Court remanded the case for a new trial on Plaintiff's deceit claim. View "Knecht v. Evridge" on Justia Law

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