Justia South Dakota Supreme Court Opinion Summaries

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

The Supreme Court affirmed the order of the circuit court compelling Defendant to return real property transferred to him by his late father and the jury verdict requiring Defendant to pay general and punitive damages to his father’s estate but reversed the court’s order requiring Defendant to pay the Estate’s attorney fees.In this case involving the consolidation of both probate and civil actions, the Estate of the decedent argued that Defendant exercised undue influence over the decedent and that Defendant converted the decedent’s property and violated his confidential relationship with the decedent in doing so. The Estate also sought punitive damages for Defendant’s alleged fraudulent behavior. The jury returned a verdict awarding the Estate general and punitive damages. The circuit court then ordered the real property previously transferred to Defendant returned to the Estate. The circuit court also awarded the estate attorney fees. The Supreme Court held that the circuit court (1) possessed subject matter jurisdiction and authority to adjudicate disposition of contrast property; (2) did not err by not granting Defendant summary judgment or by consolidating the probate and civil case; (3) properly denied Defendant’s motion for a new trial; and (4) did not have statutory authority to assess attorney fees against Defendant. View "Estate of Ducheneaux v. Ducheneaux" on Justia Law

The Supreme Court granted Plaintiff’s motion for a stay of a circuit court’s final judgment pending appeal and dismissed his appeal from a non-final judgment.In this property dispute, Plaintiff sued Defendant, and Defendant counterclaimed. The Supreme Court dismissed the complaint on summary judgment. Neither the counterclaims nor the pending motions for attorney’s fees were addressed, however. Defendant appealed. Thereafter, the circuit court filed a final judgment disposing of all pending claims. Plaintiff filed a motion to stay execution of that part of the circuit court’s final judgment ordering immediate release of the lis pendens Plaintiff had previously filed as to the property at issue in this case. The circuit court denied the stay. Plaintiff then moved the Supreme Court for special relief to grant the stay and filed a second notice of appeal as to the circuit court’s final judgment. The Supreme Court dismissed Plaintiff’s first appeal of the summary judgment because it was not final but granted his motion for special relief and stayed execution of the lower court’s judgment relating to the lis pendens, holding that the circuit court should have granted Plaintiff’s motion for a stay under the circumstances of this case. View "Healy v. Osborne" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree robbery, holding that sufficient evidence supported the conviction.On appeal, Defendant argued that the trial court erroneously admitted a surveillance video of him and an accomplice the day before the robbery. Much of the evidence directly implicating Defendant was elicited from that accomplice. Defendant argued before the Supreme Court that, without the video, there was insufficient evidence to corroborate the accomplice’s testimony. The Supreme Court disagreed, holding that even if the admission of the video was error, the error was harmless because there was evidence independent of the surveillance video that tended to affirm the accomplice’s testimony and establish Defendant’s guilt. View "State v. Dunkelberger" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree robbery, holding that sufficient evidence supported the conviction.On appeal, Defendant argued that the trial court erroneously admitted a surveillance video of him and an accomplice the day before the robbery. Much of the evidence directly implicating Defendant was elicited from that accomplice. Defendant argued before the Supreme Court that, without the video, there was insufficient evidence to corroborate the accomplice’s testimony. The Supreme Court disagreed, holding that even if the admission of the video was error, the error was harmless because there was evidence independent of the surveillance video that tended to affirm the accomplice’s testimony and establish Defendant’s guilt. View "State v. Dunkelberger" on Justia Law

The Supreme Court reversed the circuit court’s order granting full primary physical custody of Father’s minor child to the child’s maternal grandmother (Grandmother), holding that the circuit court erroneously analyzed the custody dispute using the factors set forth in Fuerstenberg v. Fuerstenberg, 591 N.W.2d 798 (S.D. 1999), which apply only in cases between parents.The circuit court applied factors taken from Fuerstenberg to the evidence and awarded Grandmother full physical custody of the child, while granting Father liberal visitation rights. The Supreme Court reversed and remanded the case, holding (1) Grandmother possessed standing as a nonparent seeking custody due to extraordinary circumstances; (2) the circuit court erroneously applied the Fuerstenberg factors; and (3) a clearer examination of the circumstances warranting a grant of custody to grandmother under S.D. Codified Laws 25-5-29 and 25-5-30 was required. View "Howlett v. Stellingwerf" on Justia Law