Justia South Dakota Supreme Court Opinion Summaries

In 2020, Cody Sturzenbecher and his mother, Judy Sturzenbecher, entered into a series of transactions with Sioux County Ranch, LLC (Sioux County) related to the purchase of their family farm from a trust. Judy bought the farm using a loan from Sioux County, then sold the property to Sioux County, which leased it to Cody. The lease included an option for Cody to purchase the property. Cody defaulted on the lease, leading Sioux County to terminate the lease and list the property for sale.The Sturzenbechers sought declaratory and injunctive relief, arguing that Judy’s conveyance of the farm to Sioux County created an equitable mortgage rather than an absolute sale. The Circuit Court of the First Judicial Circuit in Turner County, South Dakota, granted the Sturzenbechers’ request for a preliminary injunction and denied Sioux County’s motion for judgment on the pleadings. Sioux County appealed both decisions.The Supreme Court of the State of South Dakota reviewed the case and affirmed the lower court’s decisions. The court concluded that the arrangement between the Sturzenbechers and Sioux County was intended as a financing agreement rather than an absolute sale. The court found that the agreements between the parties were unambiguous but unenforceable as an absolute sale due to public policy favoring a mortgagor’s right of redemption. The court held that the Sturzenbechers were likely to succeed on their equitable mortgage claim and that the circuit court did not abuse its discretion in granting the preliminary injunction. The court also affirmed the denial of Sioux County’s motion for judgment on the pleadings, finding that the Sturzenbechers had pled sufficient facts to support their claim. View "Sturzenbecher v. Sioux County Ranch" on Justia Law

Seven members of the South Dakota Air National Guard, who also work as federal civilian employees of the Department of the Air Force, alleged that the South Dakota Adjutant General wrongfully denied them military leave while they were serving on active duty, in violation of the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA). The plaintiffs claimed they were entitled to 15 days of paid military leave each year in their civilian roles, which they were denied while on active duty.The Circuit Court of the Second Judicial Circuit, Minnehaha County, South Dakota, dismissed the USERRA claims sua sponte after a court trial, concluding that the plaintiffs must demonstrate the existence of an antimilitary animus to prevail. The court did not reach the merits of the parties’ arguments and found that the plaintiffs had failed to plead or prove such animus. The plaintiffs appealed the decision.The Supreme Court of the State of South Dakota reviewed the case and concluded that the plaintiffs are entitled to military leave. The court held that the plaintiffs did not need to show antimilitary animus because the benefit in question, military leave, is only available to members of the military. The court found that the plaintiffs' active duty under Title 10 orders was not "active Guard and Reserve duty" as defined by 10 U.S.C. § 101(d)(6), and therefore, the exception in 32 U.S.C. § 709(g)(2) did not apply. Consequently, the plaintiffs were entitled to accrue military leave under 5 U.S.C. § 6323(a)(1) while serving on active duty under Title 10. The court reversed the circuit court’s decision and remanded the case for further proceedings. View "Christiansen v. Morrell" on Justia Law

The City of Tea passed a resolution imposing a special assessment on properties abutting a road construction project, including property owned by KJD, LLC. The City found that the improvement conferred special benefits on the abutting properties beyond those experienced by the public. KJD objected to the assessment, arguing it was unconstitutional as the project did not confer a special benefit on its property. The circuit court held that KJD did not rebut the presumption that the City’s assessment was valid and did not prove by clear and convincing evidence that the City’s findings were incorrect, thus denying KJD’s objection.KJD appealed to the Supreme Court of South Dakota. The Supreme Court reviewed the case de novo, noting that the City’s findings in its resolution are presumed correct and that KJD had the burden to rebut this presumption with substantial, credible evidence. The Court found that KJD failed to present such evidence, particularly as it did not provide testimony or evidence at a trial to counter the City’s findings. The Court also noted that the City’s method of calculating the assessment based on the cost of the project was constitutionally permissible and that the City’s findings regarding the special benefits, such as improved aesthetics and safety, were supported by the project’s features.The Supreme Court of South Dakota affirmed the circuit court’s decision, holding that KJD did not meet its burden to prove that the special assessment was unconstitutional. The Court concluded that the City’s findings and the special assessment were valid and did not exceed the value of the benefits conferred on KJD’s property. View "KJD, LLC v. City of Tea" on Justia Law

On October 21, 2021, Officers Nicholas Stevens and Jason Purkapile of the Sioux Falls Police Department stopped a vehicle with an inoperable brake light. The driver, Lee Martin Holy, provided a North Dakota driver’s license but no proof of insurance. Officer Stevens returned to his patrol car to run routine checks and issue a warning ticket. Meanwhile, Officer Purkapile engaged in conversation with Holy’s grandfather, the passenger, and initiated a warrant check on him. When Officer Stevens returned to Holy’s vehicle, he asked about contraband and requested to search the car. Holy admitted to having marijuana and a medical cannabis card. A subsequent search revealed a methamphetamine pipe and methamphetamine, leading to Holy’s arrest.The Circuit Court of the Second Judicial Circuit in Minnehaha County denied Holy’s motion to suppress the evidence, concluding that the stop was not unreasonably extended by the interdiction questions. The court found that the duration of the stop was not unduly prolonged and that the warrant check on Holy’s grandfather was still pending when Holy admitted to possessing marijuana. Holy was found guilty of possession of a controlled substance and drug paraphernalia based on stipulated facts and was sentenced to supervised probation and court costs.The Supreme Court of the State of South Dakota reviewed the case and affirmed the circuit court’s decision. The court held that the interdiction questions did not extend the length of the stop beyond the time necessary to complete the mission, as the warrant check on the passenger was still pending. The court did not address whether a routine warrant check for a passenger is permissible under the Fourth Amendment, leaving that determination for another case. View "State v. Holy" on Justia Law

David and Marcia Earll's daughter, Rebecca, was killed in a car accident caused by an underinsured motorist. The Earlls sought underinsured motorist (UIM) benefits under their motor vehicle liability policy with Farmers Mutual Insurance Company of Nebraska. Farmers Mutual denied the claim based on an "owned but not insured" exclusion in the policy. The Earlls filed for a declaratory judgment, arguing that the exclusion was against public policy and that they were entitled to UIM benefits. Both parties filed motions for summary judgment. The circuit court ruled in favor of Farmers Mutual, and the Earlls appealed.The circuit court granted summary judgment to Farmers Mutual, relying on a previous decision in De Smet Insurance Company of South Dakota v. Pourier, which upheld the validity of an "owned but not insured" exclusion for UIM coverage. The Earlls argued that this decision should be overruled or distinguished, emphasizing that similar exclusions had been found to violate public policy in the context of uninsured motorist (UM) coverage.The Supreme Court of South Dakota reviewed the case and reversed the circuit court's decision. The court held that the "owned but not insured" exclusion to UIM coverage violated South Dakota public policy. The court noted that UIM coverage is intended to protect insured individuals from underinsured motorists and that such coverage follows the insured rather than the vehicle. The court overruled its previous decision in Pourier, finding it inconsistent with the statutory purpose of UIM coverage and other related decisions. The case was remanded for the circuit court to enter summary judgment in favor of the Earlls. View "Earll v. Farmers Mutual Insurance" on Justia Law

Charlene Monfore petitioned for guardianship and conservatorship over her mother, Gerda Flyte, who suffers from dementia. Gerda’s son, Roger Flyte, objected and requested to be appointed instead. After an evidentiary hearing, the circuit court found it was not in Gerda’s best interests to appoint either Charlene or Roger and instead appointed Black Hills Advocate, LLC (BHA), a for-profit corporation. Charlene appealed, arguing the court abused its discretion by not appointing her and lacked statutory authority to appoint a for-profit organization.The Circuit Court of the Seventh Judicial Circuit, Fall River County, South Dakota, initially appointed Charlene as temporary guardian and conservator. Roger objected, raising concerns about Gerda’s care under Charlene, including medical neglect and financial mismanagement. After a two-day evidentiary hearing, the court found both Charlene and Roger unsuitable due to various concerns, including Charlene’s failure to provide necessary medical care and financial mismanagement, and Roger’s financial irresponsibility and anger issues. The court appointed BHA as guardian and conservator.The Supreme Court of the State of South Dakota reviewed the case. The court held that the circuit court did not abuse its discretion in declining to appoint Charlene, given the evidence of her inadequate care and financial mismanagement. However, the Supreme Court found that SDCL 29A-5-110 does not authorize the appointment of for-profit entities as guardians or conservators, except for qualified banks or trust companies as conservators. Therefore, the appointment of BHA was reversed, and the case was remanded for further proceedings. The court also awarded Roger one-half of his requested appellate attorney fees. View "Guardianship And Conservatorship Of Flyte" on Justia Law

Chad Martin was indicted on multiple felony and misdemeanor charges following a high-speed chase during which he struck another vehicle, injuring one of its occupants. Martin pleaded guilty to one count of vehicular battery and one count of aggravated eluding. He also admitted to a part II habitual offender information. The circuit court sentenced Martin to twenty years in the state penitentiary with eight years suspended on the vehicular battery conviction and imposed a suspended two-year sentence on the aggravated eluding conviction. Martin appealed, claiming the circuit court abused its discretion by considering uncharged conduct at sentencing.The Circuit Court of the Second Judicial Circuit, Minnehaha County, South Dakota, reviewed the case. The court considered the police reports and Martin's conflicting accounts of how he came to possess the stolen vehicle. The court noted Martin's extensive criminal history, substance abuse, and the circumstances of the high-speed chase. The court sentenced Martin to twenty years in the state penitentiary with eight years suspended on the vehicular battery conviction and a suspended two-year sentence on the aggravated eluding conviction, to run concurrently but consecutively to a prior sentence for which Martin was on parole.The Supreme Court of the State of South Dakota reviewed the case. The court held that the circuit court did not abuse its discretion by considering uncharged conduct at sentencing without making explicit findings. The court found that the circuit court appropriately considered multiple sentencing factors beyond the uncharged conduct, reflecting a proper exercise of its discretion. The Supreme Court affirmed the circuit court's decision. View "State v. Martin" on Justia Law

Steven Tuopeh and Jeff Pour were involved in an altercation with Christopher Mousseaux near the Red Sea Pub in Sioux Falls, South Dakota. Mousseaux, who appeared intoxicated, swung at Tuopeh and Pour, then retreated. Tuopeh and Pour chased Mousseaux, who fell, and they proceeded to beat him. Mousseaux died from blunt force trauma. Tuopeh was charged with second-degree murder and first-degree manslaughter. Pour entered a plea bargain and was sentenced separately.The Circuit Court of the Second Judicial Circuit in Minnehaha County denied Tuopeh’s motion for statutory immunity based on self-defense, finding the State rebutted his claim by clear and convincing evidence. The court also denied Tuopeh’s motion for judgment of acquittal and several of his proposed jury instructions. The jury found Tuopeh guilty of both second-degree murder and first-degree manslaughter. The court vacated the manslaughter conviction to avoid double jeopardy and sentenced Tuopeh to life in prison for second-degree murder.The Supreme Court of the State of South Dakota reviewed the case. The court held that the circuit court did not abuse its discretion in denying the alternative counts instruction, as the jury could consider multiple counts and the court could address double jeopardy concerns post-verdict. The court also found no error in the circuit court’s handling of witness Robinson’s refusal to testify, the admission of certain evidence, and the denial of Tuopeh’s motion for acquittal. The court affirmed the circuit court’s rulings and Tuopeh’s conviction and sentence. View "State v. Tuopeh" on Justia Law

James and Amber May hired RES Construction to build their home in Sioux Falls. RES subcontracted First Rate Excavate, Inc. to install the septic system and construct the foundation. The Mays alleged that the foundation was installed several feet below grade level, causing significant drainage and septic issues that damaged their home, yard, and neighboring properties. They sued First Rate for negligence. The circuit court dismissed the claim based on the economic loss doctrine, and the Mays appealed.The Circuit Court of the Second Judicial Circuit in Lincoln County, South Dakota, dismissed the Mays' negligence claim, citing the economic loss doctrine, which limits remedies for purely economic losses to those specified in a contract. The court reasoned that the Mays lacked privity of contract with First Rate and that their claims were barred by the six-year statute of limitations.The Supreme Court of the State of South Dakota reviewed the case. The court held that the economic loss doctrine should not be expanded beyond claims arising from transactions involving the sale of defective goods under the Uniform Commercial Code (UCC). The court noted that the doctrine is designed to prevent parties from circumventing contract remedies by seeking tort remedies for economic losses. Since the Mays' claim was based on negligence and not on a UCC transaction, the economic loss doctrine did not apply. Additionally, the court found that the lack of privity between the Mays and First Rate further precluded the application of the economic loss doctrine. The Supreme Court reversed the circuit court's dismissal and remanded the case for further proceedings. View "May v. First Rate Excavate" on Justia Law

Dreau Rogers was convicted by a jury of second-degree murder for the death of his wife, Destiny Rogers, and several other offenses. Rogers claimed that a third party, Donovan Derrek, was the actual perpetrator. Rogers appealed, arguing that the circuit court erred in denying his motion for judgment of acquittal and in failing to give a spoliation instruction due to the State's handling of Derrek's phone, which was returned to Derrek and subsequently destroyed.The Circuit Court of the Fourth Judicial Circuit in Lawrence County, South Dakota, denied Rogers's motion for judgment of acquittal, finding sufficient evidence to support the jury's verdict. The court noted that the forensic evidence, including DNA and gunshot residue, supported the conclusion that Rogers, not Derrek, was the shooter. The court also found that Derrek's alibi was corroborated by text messages and testimony, and that Rogers's inconsistent statements and prior threats against Destiny further supported the conviction.The Supreme Court of South Dakota reviewed the case and affirmed the lower court's decision. The court held that the evidence was sufficient to support the conviction of second-degree murder and related charges. The court also found that the State did not violate Rogers's due process rights by returning Derrek's phone, as there was no evidence of bad faith by law enforcement. The court concluded that the circuit court did not abuse its discretion in denying Rogers's request for a spoliation instruction, as the record did not support a finding of intentional destruction of evidence by the State.The Supreme Court of South Dakota affirmed the circuit court's rulings, upholding Rogers's convictions and sentences. View "State v. Rogers" on Justia Law