Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of the City of Sioux Falls on Plaintiff’s complaint for negligence, holding that there was not a genuine issue of material fact as to whether the City’s conduct amounted to gross negligence or willful or wanton misconduct.Plaintiff was seriously injured while riding a bicycle through a public park in the City. Plaintiff sued the City for negligence. The circuit court concluded that the City was immune from liability for such negligence claims and granted summary judgment based on S.D. Codified Laws 20-9-20 and -21, which immunize a municipality for liability for negligence in connection with land open to the public for recreational use. On appeal, Defendant argued that there remained a question of fact as to whether the City was liable for his injury due to the City’s gross negligence or willful or wanton misconduct. The Supreme Court disagreed, holding that Plaintiff could not survive summary judgment when he simply alleged negligence as a cause of action and that Plaintiff failed to provide sufficient probative evidence that would permit a fining of willful or wanton misconduct on more than mere speculation or conjecture. View "Fischer v. City of Sioux Falls" on Justia Law

The Supreme Court affirmed Defendant’s conviction of second-degree murder, holding that the circuit court did not err in denying Defendant’s motion to suppress evidence obtained as a result of an investigatory stop.Prior to trial, the circuit court denied Defendant’s motion to suppress the evidence obtained as a result of the stop, concluding that the arresting law enforcement officer had reasonable suspicion to initiate the investigatory stop. The Supreme Court affirmed, holding that the officer’s suspicion was not grounded on a mere hunch, that the officer articulated facts that supported the quantum of suspicion necessary to initiate an investigatory stop, and that, under the totality of the circumstances, the investigatory stop was based on reasonable suspicion within the meaning of the Fourth Amendment. View "State v. Chase" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant, a truck driver, of operating an overweight truck on a bridge, holding that Defendant’s arguments on appeal were unavailing.Specifically, the Court held that the circuit court (1) did not err in rejecting Defendant’s argument that the truck was not subject to the weight limit posted for the bridge and finding Defendant guilty of violating S.D. Codified Laws 32-22-48; (2) did not err in denying Defendant’s request for a jury trial; and (3) did not err in denying Defendant’s motion to dismiss pursuant to S.D. Codified Laws 23A-44-5.1, otherwise known as the 180-day rule. View "State v. Johnsen" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellants’ application for a writ of mandamus to compel the Deuel County Auditor accept the three petitions submitted by Appellants seeking referendum on an ordinance amending the Wind Energy System requirements of the Deuel County Zoning Ordinance, holding that the circuit court properly denied Appellants’ petition for writ of mandamus.The Auditor rejected two of the petitions Appellants submitted, leaving an insufficient number of valid signatures to trigger a referendum election. Appellants sought a writ of mandamus to compel the Auditor to accept the rejected petitions and schedule a special election on the ordinance. The circuit court denied application, concluding that the two petitions were properly rejected because they did not substantially comply with the statutory requirements of S.D. Codified Laws 7-18A-17. The Supreme Court affirmed, holding that the petitions failed substantially to comply with the requirements of the statute. View "Thompson v. Lynde" on Justia Law

The Supreme Court affirmed the judgment of the circuit court entering an amended judgment of conviction ordering Defendant’s sentences to run concurrently to his corresponding federal sentences, holding that Defendant had no Sixth Amendment right to counsel in the circuit court proceeding to correct his sentences.Defendant pleaded guilty to kidnapping and assault. Defendant was sentenced to life imprisonment for the kidnapping and thirty years for the assault. The circuit court ordered the sentences to run consecutively to corresponding federal sentences Defendant had received for the same offenses. The Supreme Court reversed and remanded the case for resentencing, holding that a South Dakota state court may not impose a consecutive sentence in state court when a defendant has been sentenced for the same offenses in federal court. After Defendant was resentenced, he argued that the circuit court’s failure to provide court-appointed counsel in the sentence correction proceeding violated his Sixth Amendment right to counsel. The Supreme Court disagreed, holding that the sentence correction proceeding was not a critical stage in which Defendant had a Sixth Amendment right to court-appointed counsel. View "State v. Red Kettle" on Justia Law

The Supreme court affirmed the judgment of the circuit court granting summary judgment in favor of Defendants in this action for summary judgment, holding that an exculpatory clause in a contract between the parties unambiguously insulated Defendants for liability in tort and contract for their good-faith acts and failures to act under the authority granted to them by the contract and contract documents.At issue was the enforceability of exculpatory clauses insulating a third party from claims of negligent design and negligent administration and interpretation of a contract. The Supreme Court held that Defendants, who were hired by the Oglala Sioux Tribe to design a road reconstruction project, were entitled to summary judgment where (1) Plaintiff failed to establish that the clause at issue contravened public policy; (2) Defendants established a prima facie case of good faith, and there was no material issue of fact in dispute on the issue of Defendants’ good-faith acts and failures to act in the interpretation and application of the contract documents; and (3) no genuine material issue existed for trial that Defendants’ design and drafting fell below a professional standard of care. View "Domson, Inc. v. Kadrmas Lee & Jackson, Inc." on Justia Law

The Supreme Court reversed in part and affirmed in part the circuit court’s grant of summary judgment in favor of Larry Weisser, holding that Kayla Fluth’s satisfaction of judgment against Schoenfelder Construction, Inc. did not automatically discharge Weisser.Fluth sued Weissar and Schoenfelder to recover damages for flooding in her basement caused by a waterline leak on Weissar’s property. Prior to trial, Fluth accepted Schoenfelder’s offer of judgment for $7,500 and filed a satisfaction of judgment. Thereafter, Weisser filed a motion for summary judgment, arguing that a satisfaction of judgment discharges all other joint tortfeasors from liability. The circuit court granted the motion. The Supreme Court affirmed in part and reversed in part, holding that Fluth did not discharge Weisser from liability if the satisfaction of judgment did not reflect a full satisfaction of Fluth’s damages, and on remand the court must determine whether Schoenfelder’s satisfaction of judgment was a full or partial satisfaction. View "Fluth v. Schoenfelder" on Justia Law

In this case asserting breach of contract and fraud, the Supreme Court reversed the order of the circuit court granting the motion filed by Portable Lift Equipment Inc. (PLE) for a new trial on the issue of damages, holding that the circuit court erred in concluding that there was insufficient evidence to support the compensatory awards.International Services Group Corp. (ISG) contracted with PLE to build two observation platforms for use by law enforcement at a festival held in Puerto Rico. PLE failed to deliver the agreed-upon platforms and instead delivered a contractually noncompliant platform. ISG sued PLE and its president. The jury found in favor of ISG and awarded both compensatory and punitive damages. PLE later filed a motion for a new trial. The circuit court granted a new trial on the issue of damages, expressing concern that it could not replicate the jury’s calculations, and denied the motion on the issue of liability. The Supreme Court reversed, holding that the compensatory damages awards provided by the jury could be explained by the evidence, and the compensatory damages did not impermissibly taint the punitive-damages awards. View "ISG, Corp. v. PLE, Inc." on Justia Law

The Supreme Court dismissed the State’s intermediate appeal challenging the circuit court’s reversal of the magistrate court’s order denying Defendant’s motion to suppress, holding that there was no basis for an appeal to this Court at the present stage of the proceedings.Defendant was charged with driving under the influence of alcohol. Defendant filed a motion to suppress the evidence obtained from the traffic stop, arguing that police officers lacked reasonable suspicion. The magistrate court denied the motion. Defendant was then convicted and sentenced. Defendant appealed, and the circuit court reversed and remanded the judgment. The State petitioned for an intermediate appeal, arguing that the Supreme Court had jurisdiction to hear an appeal under S.D. Codified Laws 23A-32-5. The Supreme Court dismissed the appeal, holding that no appeal can lie from the circuit court’s remand order. View "State v. Sharpfish" on Justia Law

After the United States Supreme Court vacated the judgment of the Supreme Court affirming the circuit court’s summary judgment in favor of Defendants, the Supreme Court reversed the circuit court’s grant of summary judgment and remanded the case for proceedings consistent with the United States Supreme Court’s opinion.In 2017, the Supreme Court affirmed the circuit court’s summary judgment in favor of Defendants, holding that the statutory scheme requiring internet sellers with no physical presence in South Dakota to collect and remit sales tax violated the Commerce Clause. The United States Supreme Court vacated the judgment and remanded the case. The State subsequently filed a motion requesting the Supreme Court to remand the matter for further proceedings. Defendants filed no response. Accordingly, the Supreme Court dispositively remanded this case for further proceedings not inconsistent with the United States Supreme Court’s opinion. View "State v. Wayfair Inc." on Justia Law