Justia South Dakota Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant’s convictions for unauthorized ingestion of a controlled substance and possession of two ounces or less of marijuana but reversed and remanded for a new trial Defendant’s conviction for first-degree manslaughter, holding that the circuit court erred in instructing the jury on first-degree manslaughter.After the State concluded its case-in-chief, Defendant submitted a proposed jury instruction on excusable homicide. The circuit court denied Defendant’s proposed instruction, noting that it was submitted after the State had rested and determining that defendant’s conduct was unlawful. The Supreme Court held that because the evidence presented a theory for the jury’s consideration whether the homicide was accidental and excusable, the circuit court erred in failing to give the excusable homicide instruction, and the error prejudiced Defendant. The Court further held that the circuit court did not abuse its discretion by denying Defendant’s motions for mistrial. View "State v. Randle" on Justia Law

The Supreme Court affirmed the sentence imposed in connection with Defendant’s conviction for third-degree burglary, holding that the sentencing court had authority to alter its original sentence and that Defendant did not establish that the sentencing court abused its discretion in imposing the sentence.After Defendant pleaded guilty to third-degree burglary as part of a plea agreement, the court sentenced him to five years’ imprisonment with three and one-half years suspended. Before exiting the courtroom in the custody of the sheriff, Defendant “flipped off” the circuit court judge. The court then summoned Defendant back to counsel’s table and resentenced him, imposing the entry five-year term. The court then granted a resentencing hearing and imposed a sixty-month sentence with forty months suspended. The Supreme Court affirmed the sentence, holding (1) under the circumstances, no formal break in the proceedings occurred when Defendant made his obscene gesture, and therefore, the circuit court had the authority to modify Defendant’s sentence; and (2) the court properly relied on S.D. Codified Laws 23A-27-19 to reduce Defendant’s five-year sentence to a sentence of sixty months with forty months suspended. View "State v. Ross" on Justia Law