Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court granting the State's motion to dismiss Appellant's civil action challenging a Department of Corrections (DOC) administrative policy relating to the method and procedures for carrying out capital sentences, holding that provisions of S.D. Codified Laws chapter 23A-27A, rather than the DOC policy, vest members of the executive branch with the authority to carry out a capital sentence.Appellant was convicted of first-degree murder and sentenced to death. Appellant later brought his civil action claiming that a written policy issued by the DOC relating to the execution of a condemned inmate was invalid because it was not promulgated within the rule-making requirements of the state's Administrative Procedure Act (APA). The circuit court dismissed the complaint, determining that the Policy was not subject to the APA and that the authority of the DOC to carry out a death sentence was derived from S.D. Codified Laws 23A-27A-32, whose provisions were self-executing. The Supreme Court affirmed, holding that the DOC policy was not subject to the APA's rule-making requirements. View "Rhines v. S.D. Department Of Corrections" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of the Estate of Kenneth Stoebner in this breach of fiduciary duty claim against Curtis Huether, who served as Stoebner's attorney-in-fact under a power of attorney, holding that summary judgment was properly granted.Under his role of Stoebner's attorney-infant Huether executed a sale of Stoebner's real property to himself four days before Stoebner died. Stoebner's Estate commenced this action for breach of fiduciary duty, alleging that Huether engaged in an act of self-dealing when he executed the purchase agreement and warranty deed in his own favor as the attorney-in-fact for Stoebner. The circuit court granted summary judgment to the Estate and ordered that the sale be declared null and void. The Supreme Court affirmed, holding that no genuine disputes of material fact existed regarding Huether's fiduciary duty to Stoebner to not engage in acts of self-dealing under the provisions of the power of attorney. View "Estate of Stoebner v. Huether" on Justia Law

The Supreme Court reversed in part the circuit court's judgment granting Defendants summary judgment in part and, after a trial, entering a judgment consistent with the jury verdict, holding that a new trial on Plaintiffs' conversion and unjust enrichment claims was necessary.Plaintiffs loaned Defendants nearly $1.2 million, securing the loans with fifty-five promissory notes. Plaintiffs later sued Defendants for breach of contract, unjust enrichment, and conversion. Defendants counterclaimed for conversion and unjust enrichment. The circuit court granted Defendants summary judgment in part, dismissing forty-eight of the promissory notes as time barred and concluding that the related mortgage was unenforceable. After a trial, the jury returned a verdict for Plaintiffs on their breach of contract claim, rejected their claim for conversion, and awarded Defendants $135,000 on their conversion counterclaim. The jury then rendered an advisory verdict for Defendants as to the parties' competing claims for unjust enrichment. The Supreme Court reversed in part, holding that the circuit court (1) abused its discretion by giving a missing witness instruction at trial, (2) erred by allowing the jury to determine the date to begin calculating interest on the enforceable promissory notes, and (3) erred in allowing the jury to consider evidence of the time-barred notes when considering Plaintiffs' claims of unjust enrichment. View "Mealy v. Prins" on Justia Law

The Supreme Court affirmed the judgment of the trial court granting summary judgment in favor of Defendants and dismissing Plaintiff's suit claiming that he was financially damaged by Defendants' fraud and conspiracy and deprived of control over the family ranch, holding that the circuit court properly concluded that Plaintiff's suit was time barred.This case arose out of a family dispute over ownership and control of a family ranch. Plaintiff sued his mother, brothers, former attorney, and two business entities charging Defendants with, among other things, conversion, fraud, and conspiracy to commit fraud and requesting punitive and compensatory damages. The circuit court granted Defendants' motions for summary judgment on all claims, concluding that Plaintiff's claims were time barred. The circuit court then granted Defendants' motions for attorney fees, concluding that Plaintiff's lawsuit was frivolous and malicious. The Supreme Court affirmed, holding that the circuit court (1) properly concluded that Plaintiff's suit was time barred; and (2) did not abuse its discretion by awarding attorney fees to Defendants. View "Healy v. Osborne" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of Mid-Century Insurance Company and dismissing Christina Blanchard's bad-faith complaint, holding that the circuit court properly granted summary judgment for Mid-Century.In her complaint, Blanchard alleged that Mid-Century pursued a "baseless and meritless appeal" from a decision of the South Dakota Department of Labor awarding Blanchard workers' compensation benefits. On appeal, Blanchard argued, among other things, that the circuit court erred in excluding evidence under the litigation conduct rule. The Supreme Court concluded that the circuit court's exclusion of the evidence under the litigation conduct rule was determinative of the appeal, and therefore it was unnecessary to discuss Blanchard's other claims of error, holding that the circuit court properly excluded the evidence and properly granted summary judgment based upon the other undisputed facts in the record. View "Blanchard v. Mid-Century Insurance Co." on Justia Law

The Supreme Court affirmed Defendant's convictions of attempted first-degree murder, aggravated assault on a law enforcement officer, and other offenses, holding that the circuit court did not err by denying Defendant's motions to suppress and did not abuse its discretion by denying Defendant's proposed jury instructions on lesser-included offenses.Prior to trial, Defendant filed three motions to suppress his statements to law enforcement and also moved to suppress evidence derivative of his arrest on the basis that the officer engaged in racial profiling as the basis for the traffic stop. The circuit court denied the motions to suppress. Defendant was subsequently convicted. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Defendant's motions to suppress; and (2) did not err in refusing to give Defendant's proposed lesser included offense instructions. View "State v. Willingham" on Justia Law

The Supreme Court reversed the judgment of the circuit court ordering dissolution and the sale of Dragpipe Saloon, LLC's assets, holding that the drastic remedy of judicial dissolution was not supported by the evidence in this case.In their efforts to sell their membership interests two members of Dragpipe requested judicial dissolution and an order authorizing the sale of Dragpipe's assets. The circuit court granted the request for dissolution, concluding that judicial dissolution was authorized under S.D. Codified Laws 47-34A-801(a)(4)(i) and (iii) because Dragpipe's economic purpose was unreasonably frustrated and because it was not reasonably practicable to carry on its business under the provisions of the operating agreement. The Supreme Court reversed, holding (1) the circuit court erred in its interpretation of the operating agreement and in its application of sections 47-34A-801(a)(4)(i) and (iii); and (2) the economic purpose was not likely to be unreasonably frustrated by Dragpipe's continued operation, and the LLC was operating within the purposes stated in the operating agreement. View "Dysart v. Dragpipe Saloon, LLC" on Justia Law

In this personal injury action, the Supreme Court affirmed the judgment of the circuit court in favor of Plaintiff, holding that the circuit court did not abuse its discretion in denying Defendants' motion to exclude testimony from Plaintiff's medical providers regarding the extent and permanency of his injuries and that the jury's verdict was not the result of passion or prejudice.Specifically, the Court held (1) the circuit court properly exercised its discretion in allowing Plaintiff's treating providers to testify about the permanency of his injuries, and the court's decision to allow the undisclosed opinions by Plaintiff's regular medical provider about the impact of Plaintiff's injuries did not create prejudice sufficient to warrant reversal; and (2) the evidence presented to the jury supported its verdict and failed to support Appellants' claim that the jury acted with passion or prejudice. View "Weber v. Rains" on Justia Law

The Supreme Court denied Defendant's motion for a certificate of probable cause to appeal the denial of habeas corpus relief from his kidnapping convictions, holding that Defendant's habeas claims were "clearly procedurally defaulted."Defendant's criminal judgment was final more than two years before the effective date of S.D. Codified Laws 21-27-3.3, the statute of limitations enacted in 2012, cutting off Defendant's ability to commence his habeas action. While the decision in Hughbanks v. Dooley, 887 N.W.2d 319 (S.D. 2016), gave Defendant until July 1, 2014 to commence his action Defendant did not commence it until January 2015. Defendant argued before the Supreme Court that the statute of limitations did not begin to run until he was appointed counsel who could recognize the "factual predicate[s]" for his habeas claims. The Supreme Court held (1) the timeframe from which section 21-27-3.3(4) begins to run is when the facts, rather than the legal basis, giving rise to potential claims are either known or could have been discovered with due diligence; and (2) Defendant knew the evidentiary facts supporting his claims at the time his judgment was entered in 2007, and therefore, his habeas claims remained "clearly procedurally defaulted" under the statute. View "Asmussen v. Young" on Justia Law

The Supreme Court reversed the order of the magistrate court that Defendant's motion to suppress should be granted in accordance with an earlier order of the circuit court, holding that Defendant's constitutional rights were not violated, and therefore, Defendant's motion to suppress should have been denied.Defendant was charged with driving under the influence of alcohol. Defendant filed a motion to suppress evidence as a result of his encounter with a police officer, arguing that he was not detained based on reasonable suspicion, and therefore, the stop of his vehicle violated the Fourth Amendment of the federal constitution and Article VI of the state constitution. The magistrate court denied the motion to suppress and entered a judgment of conviction. The circuit court reversed and ordered that Defendant's motion to suppress should be granted. The magistrate court then entered its order acting in accordance with the circuit court's order and granted Defendant's motion to suppress. The Supreme Court reversed, holding (1) this Court had jurisdiction to hear the State's appeal; and (2) the officer developed a reasonable suspicion of criminal activity before seizing Defendant, and therefore the evidence from the stop should not have been suppressed. View "State v. Sharpfish" on Justia Law