Justia South Dakota Supreme Court Opinion Summaries

In this divorce action, the Supreme Court affirmed the circuit court’s valuation of a bank account on a date other than the date of divorce, the decision to recapture into the marital estate the value of home improvements made to a third party’s rental property, and the valuation of Husband’s three business interests. The Court held that the circuit court did not abuse its discretion when it (1) included the value of the bank account from eleven months before trial; (2) included $15,000 of improvements made to Husband's father’s rental property; and (3) valued Husband's business interests. View "Giesen v. Giesen" on Justia Law

The Supreme Court affirmed the judgment of the habeas court denying Appellant’s petition for a writ of habeas corpus. After a jury trial, Appellant was convicted of second-degree murder and aggravated assault. In his habeas petition, Appellant argued that the circuit court committed errors during the jury selection process that warranted a new trial and that his counsel provided constitutionally ineffective assistance. The habeas court concluded (1) the circuit court committed errors during the jury selection process, but the errors were not structural and Appellant did not prove prejudice; and (2) Appellant failed to prove that counsel was ineffective during the jury selection process. The Supreme Court affirmed, holding (1) the circuit court’s errors during the jury selection process were not structural and were harmless; and (2) Appellant failed to show that he receive ineffective assistance of counsel. View "Miller v. Young" on Justia Law

The Supreme Court affirmed the the circuit court’s classification and division of property in this divorce case in all but one respect as regards a clerical issue, which the Court remanded for clarification.Husband and Wife held most of their assets separately throughout their eighteen-year marriage. In granting them a divorce, the circuit court classified most of their assets as marital property and divided them equally. The Supreme Court held (1) the circuit court did not abuse its discretion in classifying the parties’ separately held assets as marital property; and (2) Wife was not entitled to relief on her arguments relating to the circuit court’s division and valuation of property with the exception of her argument that the circuit court erred in failing to divide and allocate three liabilities. Because the court’s failure to allocate these debts may have been a clerical error, the Supreme Court remanded the issue for the circuit court’s classification. View "Arendt v. Chamberlain" on Justia Law

The Supreme Court affirmed the order of the circuit court ordering Eryn Winegeart to sell real estate she owned jointly with her former spouse, Weston Winegeart, holding that the court did not err by ordering Eryn to sign a purchase agreement signed by a third party.After the parties underwent mediation, Weston signed an agreement with a real-estate agent to list the jointly owned real estate, and the listing agreement included a commission for the realtor. After the third party signed the purchase agreement, Eryn refused to sign it, asserting that during mediation Weston had orally agreed to sell the property without paying for a realtor. The circuit court found that the parties had not entered into an enforceable oral agreement in regard to realtor fees and ordered Eryn to sign the purchase agreement. The Supreme Court affirmed, holding that the circuit court did not err by entering its order requiring Eryn to sign the purchase agreement. View "Winegeart v. Winegeart" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of second-degree murder. The Court held that the circuit court did not err in (1) failing to dismiss the indictment on the ground that Defendant was not given notice of the coroner’s release of the body because Defendant failed to demonstrate prejudice; (2) denying Defendant’s motion for judgment of acquittal because the evidence was sufficient to support the verdict; and (3) admitting autopsy photographs into evidence because Defendant failed to show that the evidence was unduly prejudicial. View "State v. Quist" on Justia Law

The Supreme Court affirmed the circuit court’s partial denial of Plaintiffs’ partial denial of their request for preliminary injunctive relief against Defendant, their former agent, holding that the circuit court did not err by enjoining Defendant only from soliciting business from Plaintiffs’ existing customers without also enjoining Defendant from selling to those customers.Plaintiffs, Farm Bureau Life Insurance Co. and Farm Bureau Property and Casualty Insurance Co., argued in their complaint that Defendant, after leaving Farm Bureau, breached the agency contracts he entered into with Farm Bureau by selling insurance policies to clients to whom he had previously sold Farm Bureau policies. In partially denying Plaintiffs’ request for injunctive relief, the circuit court concluded that portions of the agency contracts that prohibited Defendant from selling to Farm Bureau’s existing customers was an invalid restraint on trade under S.D. Codified Laws chapter 53-9. The Supreme Court affirmed, holding that the plain meaning of section 53-9-12 supported the circuit court’s decision to adhere to that statute’s language. View "Farm Bureau Life Insurance Co. v. Dolly" on Justia Law

The Supreme Court reversed the judgment of the circuit court granting Defendant’s motion to suppress evidence found in the vehicle Defendant was driving, holding that, contrary to the circuit court’s finding, Defendant’s traffic stop was not unlawfully extended.Defendant was indicted on four felony drug charges after controlled substances were found in the vehicle she was driving. The circuit court granted Defendant’s motion to suppress, determining that the officer that stopped the vehicle unlawfully prolonged the traffic stop to question Defendant, conduct standard field sobriety tests, and call for a drug dog without reasonable suspicion of drug activity. The Supreme Court reversed, holding that the officer’s decision to extend the initial traffic stop to question Defendant about drug activity and to conduct the drug dog sniff was supported by reasonable suspicion, and therefore, the traffic stop was not unlawfully extended. View "State v. Barry" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Petitioners' petition for a writ of mandamus, in which Petitioners sought to force Waubay Township to maintain roads accessing their property. In denying the writ, the circuit court determined that the Township had no duty to maintain the roads because they were not part of the township road system. The Supreme Court affirmed, holding (1) Petitioners failed to meet their burden of proving that the Township was required to maintain the roads under S.D. Codified Laws 31-13-1; and (2) therefore, the circuit court did not abuse its discretion in denying the petition for writ of mandamus. View "Coester v. Waubay Township" on Justia Law

The Supreme Court affirmed the order of the circuit court ruling that an option agreement was void and ordering Wayne Snaza, as trustee of the Dennis Snaza Family Trust, to distribute the net income and residue of the principle of the trust to the beneficiaries upon completion of its term.Wayne gave notice of his intent to exercise his rights under the option agreement to purchase the real property held by the Trust. The circuit court concluded that the option agreement was void because it could not survive the contemporaneous execution of deeds to the same real property, and even if the option agreement was valid, Wayne waived his rights when the real property was transferred to the Trust. The Supreme Court affirmed, holding (1) because Wayne presented no evidence to rebut the presumption that the property was already conveyed before the option agreement became effective, the circuit court did not err in finding the option agreement invalid; and (2) the circuit court did not violate Wayne’s due-process rights or abuse its discretion by ordering Wayne to distribute the Trust at the conclusion of its term and in accordance with the Trust instrument. View "In re Dennis Snaza Family Trust" on Justia Law

The Supreme Court affirmed the circuit court’s order affirming the Department of Labor’s grant of summary judgment to Fall River County and against Plaintiff, a former County employee, who alleged that the County committed an unfair labor practice in refusing to hold a hearing on her grievance. In dismissing Plaintiff’s petition, the Department concluded that Plaintiff’s claim did not an allege an unfair labor practice because Plaintiff was not an employee at the time she filed her formal grievance. The circuit court affirmed, concluding that the Department of Labor lacked jurisdiction to hear Plaintiff’s claim. The Supreme Court affirmed, holding that the County’s refusal to provide a grievance hearing to a former employee did not constitute an unfair labor practice. View "Winslow v. Fall River County" on Justia Law