Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the circuit court granting summary judgment in favor of the City of Box Elder on William Maher’s claim that the City negligently operated its water system and caused his waterlines to break, holding that the public duty rule did not apply in this case.In moving for summary judgment, the City argued that the public duty rule precluded imposition of a duty because Maher failed to establish that the City owed him a special duty. The circuit court agreed with the City and granted summary judgment. The Supreme Court reversed, holding (1) the public duty rule did not apply in this case; and (2) the City owed Maher a duty to use reasonable care in its operation of its water system. View "Maher v. City of Box Elder" on Justia Law

The Supreme Court affirmed Defendant’s sentence, imposing in connection with his conviction of second-degree rape, of forty years in the state penitentiary, with five years suspended, to run consecutive to the prison term Defendant was currently serving in Iowa for offenses involving the same victim, holding that the sentence was not cruel and unusual in violation of the Eighth Amendment.Specifically, the Supreme Court held (1) after weighing the gravity of the offense against the sentence Defendant received, the circuit court did not violate Defendant’s constitutional rights by imposing a sentence within the authorized fifty-year maximum; and (2) the circuit court did not abuse its discretion in sentencing Defendant. View "State v. Yeager" on Justia Law

The Supreme Court affirmed the order of the circuit court affirming the decision of the South Dakota Retirement System (SDRS) denying Debra Lee Anderson’s application for survivor spouse benefits under Deborah Cady’s retirement plan with the SDRS, holding that Anderson was not entitled to receive survivor benefits.Anderson and Cady both worked for the Rapid City Police Department. In 2012, Cady retired from the department. In 2015, Anderson and Cady married. In 2017, Cady died. Anderson applied for survivor spouse benefits, but the SDRS denied the application because Anderson and Cady were not married at the time of Cady’s retirement and because Anderson did not meet the definition of a “spouse” under S.D. Codified Laws 3-12-47(80). The South Dakota Officer of Hearing Examiners and circuit court both affirmed the SDRS. The Supreme Court affirmed, holding (1) under the relevant statutes, Anderson could not meet the definition of “spouse” and therefore was not entitled to Cady’s survivor benefits under South Dakota law; and (2) there was no discrimination on the basis of Anderson’s gender or sexual orientation. View "Anderson v. South Dakota Retirement System" on Justia Law

The Supreme Court affirmed the circuit court’s orders granting Defendants’ motion to vacate default judgments and in granting summary judgment for Defendants in this personal injury action, holding that summary judgment was proper because Plaintiff did not resist summary judgment with specific facts showing a genuine issue for trial on the question of causation for his claimed injuries.Plaintiff brought this action following a car accident and obtained default judgments against Defendants. Defendants filed a motion to set aside the default judgments, which the circuit court granted. Thereafter, Defendants moved for summary judgment not he grounds that Plaintiff could not prove causation absent an expert opinion showing his injuries were caused by the collision. The Supreme Court affirmed, holding (1) the circuit court did not err in concluding that expert testimony was necessary to prove the accident proximately caused Plaintiff’s injuries; and (2) under the circumstances, the court did not err in granting Defendants’ motion to set aside the default judgment or in denying Defendant’s motion to reinstate the default judgment. View "Cooper v. Brownell" on Justia Law

The Supreme Court affirmed Defendant’s conviction for unauthorized possession of a controlled substance and admitting to five prior felony convictions but reversed Defendant’s sentence, holding that the record lacked a sufficient statement of aggravating circumstances that would justify a departure from a presumptive sentence.Here, the judgment and sentence contained a purported statement of aggravating circumstances, but it was not provided by the sentencing court on the record. The Supreme Court held (1) under S.D. Codified Laws 22-6-11, the sentencing court, not the prosecutor, must state on the record the aggravating circumstances impacting public safety as a predicate to departing from a presumptive sentence and include those factors in the written judgment; and (2) the circuit court incorrectly determined that section 22-6-11 did not apply and in sentencing Defendant as though he had actually been convicted of a class C felony, rather than a class 5 felony. View "State v. Roedder" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing this divorce action between Charlotte Anderson and Arthur Anderson, holding that the circuit court did not err in concluding that Arthur’s death deprived it of jurisdiction to act.After Charlotte brought this action, the parties informed the court that all issues associated with the divorce had been stipulated to. As relevant to this appeal, the parties agreed that the judgment and decree of divorce would be entered nunc pro tunc to March 1, 2018 and apply retroactively to December 31, 2017. The stipulation was read into the record, and the court orally bound the parties to the stipulation, but before the decree was entered, Arthur died. The circuit court dismissed the divorce action, concluding that it lacked jurisdiction to enter a decree of divorce because Arthur’s death had dissolved the marriage. The Supreme Court affirmed, holding that Arthur’s death abated the jurisdiction of the circuit court to enter a nunc pro tunc decree. View "Andersen v. Andersen" on Justia Law

The Supreme Court affirmed the circuit court’s judgment convicting Defendant of first-degree rape, multiple counts of sexual contact with a child, and possessing, manufacturing, or distributing child pornography, holding that the circuit court did not violate Defendant’s right to a public trial when it ordered the partial closure of the courtroom during the minor victim’s testimony.On appeal, Defendant argued that the circuit court erred in partially closing the courtroom in violation of his Sixth Amendment right to a public trial and that the court erred in denying his motion to suppress his non-custodial statement to a law enforcement officer. The Supreme Court affirmed, holding (1) there was no violation of Defendant’s Sixth Amendment right to a public trial; and (2) the absence of any custodial interrogation rendered Defendant’s second argument unsustainable under Miranda v. Arizona, 384 U.S. 436 (1996), and Edwards v. Arizona, 451 U.S. at 485-85 (1990). View "State v. Uhre" on Justia Law

The Supreme Court reversed the decision of the circuit court affirming the decision of the South Dakota Department of Labor and Regulation awarding partial summary judgment in favor of Claimant for existing medical expenses she incurred after she suffered a workplace injury to her right foot that required surgery.This appeal concerned Claimant’s second motion for partial summary judgment to recover existing medical expenses after the Department first award partial summary judgment for Claimant’s incurred medical expenses. Employer and its insurer paid the outstanding medical expenses and then argued that a decision on the second motion was unnecessary because the issue was moot. The Department granted partial summary judgment in favor of Claimant. The circuit court affirmed. The Supreme Court reversed the circuit court’s judgment affirming the Department’s decision and remanded to the circuit court with instructions that the court order the Department to vacate its order and dismiss Claimant’s claim for medical expenses, holding that the claim for medical expenses set forth in Claimant’s motion for partial summary judgment became moot prior to the Department’s final order granting summary judgment and was moot when the circuit court reviewed it on appeal. View "Skjonsberg v. Menard, Inc." on Justia Law

The Supreme Court affirmed the decision of the circuit court affirming in part and reversing in part the decision of the South Dakota Department of Revenue issuing Carsforsale.com a certificate of assessment for alleged use tax violations, holding that Carsforsale was not entitled to an advertising exemption or a sale-for-resale exemption.Carsforsale was a web-based business that offered dealers and individuals an online forum to advertise their vehicle for sale and also provided website hosting, social media integration, and other services. The Department found that Carsforsale was not entitled to an advertising exemption on disputed services and dismissed Carsforsale’s argument that the purchases of domain names were exempt under the sale-for-resale exemption. The Supreme Court held (1) Carsforsale was not entitled to the advertising exemption; and (2) Carsforsale was not entitled to the sale-for-resale exemption. View "Carsforsale.com v. South Dakota Department of Revenue" on Justia Law

The Supreme Court affirmed the decision of the circuit court determining that the Minnehaha County Board of Commissioners properly granted two drainage permits to Jason and Vernon McAreavey and dismissing Plaintiff’s claims for damages, injunctive relief, and abatement of nuisance against the McAreaveys and the Minnehaha County Board of Commissioners, holding that the circuit court’s judgment was not in error.Plaintiff appealed the County’s approvals of the McAreaveys’ two drainage permits and also filed an action for declaratory judgment against the McAreaveys and the County, alleging that previously issued drainage permits were null and void due to a lack of notice. The circuit court affirmed the County’s approval of the permit applications and granted summary judgment on Plaintiff’s claims for injunctive relief and abatement of a nuisance. The Supreme Court affirmed, holding (1) the circuit court did not err in affirming the County’s approval of the two drainage applications under the civil law rule; (2) the County’s assertion of jurisdiction was proper; (3) the circuit court did not err in granting summary judgment on Plaintiff’s claim for damages; and (4) the circuit court properly granted summary judgment on Plaintiff’s remaining claims. View "In re Drainage Permit of McAreavey" on Justia Law