Justia South Dakota Supreme Court Opinion Summaries

McKie Ford Lincoln, Inc. filed suit against Scott Hanna, its former sales manager, and Gateway Automotive, LLC, the automobile dealership Hanna owned, seeking to enforce a non-competition and disclosure agreement that Hanna signed when he was hired by McKie Ford. Hanna and Gateway filed a counterclaim against McKie Ford alleging a cause of action for barratry. The parties filed cross-motions for summary judgment. The circuit court granted the summary judgment motion filed by Hanna and Gateway and denied McKie Ford’s motion. The Supreme Court affirmed the denial of McKie Ford’s motion for summary judgment, holding that Hanna was no longer subject to the non-compete agreement when he commenced ownership and operation of Gateway, and therefore, Hanna was entitled to judgment as a matter of law. View "McKie Ford Lincoln, Inc. v. Hanna" on Justia Law

The Supreme Court affirmed Defendant’s convictions for first-degree murder, first-degree burglary, and second-degree rape, holding that the circuit court did not commit prejudicial error in any of the issues raised by Defendant.On appeal, Defendant argued that the circuit court committed several errors in its evidentiary rulings, erred by denying Defendant’s motions for mistrial, erred in denying Defendant’s proposed jury instructions, and erred by denying Defendant’s motion for judgment of acquittal. Defendant further argued that the accumulation of the errors constituted reversible error. The Supreme Court disagreed, holding that there was no prejudicial error. View "State v. Kryger" on Justia Law

In this second appeal regarding a contract dispute, the Supreme Court held that the circuit court did not err, on remand, in concluding that the contract created a right of first refusal and that the contract was void as an unreasonable restraint against alienation. The court held (1) the circuit court did not err when it held that the parties intended to create a right of first refusal; (2) the circuit court did not err when it ruled that the contract constituted an unreasonable restraint on alienation and repugnant to the interest created; and (3) the court did not err when it refused to narrow the scope of the alienation to comply with S.D. Codified Laws 43-5-1 or another reasonable limitation. View "Laska v. Barr" on Justia Law

In this second appeal regarding a contract dispute, the Supreme Court held that the circuit court did not err, on remand, in concluding that the contract created a right of first refusal and that the contract was void as an unreasonable restraint against alienation. The court held (1) the circuit court did not err when it held that the parties intended to create a right of first refusal; (2) the circuit court did not err when it ruled that the contract constituted an unreasonable restraint on alienation and repugnant to the interest created; and (3) the court did not err when it refused to narrow the scope of the alienation to comply with S.D. Codified Laws 43-5-1 or another reasonable limitation. View "Laska v. Barr" on Justia Law

At issue was the Meade County Board of County Commissioners’ order approving incorporation of a proposed municipality of Buffalo Chip City and setting an election for voters to decide whether to assent to incorporation.After denying a request to stay the election, the election was held, and a majority of voters chose to incorporate Buffalo Chip City. The Board then declared Buffalo Chip City formally incorporated. The circuit court heard Appellees’ appeal and issued a judgment declaring that the Board’s order was invalid, that the election was a nullity, and that Buffalo Chip City was void. The Supreme Court reversed and vacated the circuit court’s judgment, holding that S.D. Codified Laws 9-3-20 requires that any action challenging Buffalo Chip City’s incorporation be brought by the State, and because Appellees did not bring their suit on behalf of the State, the circuit court lacked subject-matter jurisdiction. View "Lippold v. Meade County Board of Commissioners" on Justia Law

At issue was the Meade County Board of County Commissioners’ order approving incorporation of a proposed municipality of Buffalo Chip City and setting an election for voters to decide whether to assent to incorporation.After denying a request to stay the election, the election was held, and a majority of voters chose to incorporate Buffalo Chip City. The Board then declared Buffalo Chip City formally incorporated. The circuit court heard Appellees’ appeal and issued a judgment declaring that the Board’s order was invalid, that the election was a nullity, and that Buffalo Chip City was void. The Supreme Court reversed and vacated the circuit court’s judgment, holding that S.D. Codified Laws 9-3-20 requires that any action challenging Buffalo Chip City’s incorporation be brought by the State, and because Appellees did not bring their suit on behalf of the State, the circuit court lacked subject-matter jurisdiction. View "Lippold v. Meade County Board of Commissioners" on Justia Law

At issue in this negligence case was whether the circuit court committed reversible error when it did not instruct the jury on the doctrine of res ipsa loquitur.Plaintiff was at a Cabela’s store when she brushed a heavy drop-down steel receiver hitch, which fell and injured Plaintiff. Plaintiff sued Cabela’s for negligence. During the settling of jury instructions, Plaintiff requested two pattern jury instructions on the doctrine of res ipsa loquitur, arguing that the instructions were appropriate because the only evidence of negligence was the fact that the hitch, which was under Cabela’s control, fell. The circuit court concluded that the instructions were not warranted by the evidence presented at trial. The Supreme Court affirmed, holding that the circuit court did not commit reversible error when it refused Plaintiff’s requested instructions because Plaintiff’s evidence left room for different presumptions or inferences negating the applicability of the doctrine. View "Steilen v. Cabela’s Wholesale, Inc." on Justia Law

At issue in this negligence case was whether the circuit court committed reversible error when it did not instruct the jury on the doctrine of res ipsa loquitur.Plaintiff was at a Cabela’s store when she brushed a heavy drop-down steel receiver hitch, which fell and injured Plaintiff. Plaintiff sued Cabela’s for negligence. During the settling of jury instructions, Plaintiff requested two pattern jury instructions on the doctrine of res ipsa loquitur, arguing that the instructions were appropriate because the only evidence of negligence was the fact that the hitch, which was under Cabela’s control, fell. The circuit court concluded that the instructions were not warranted by the evidence presented at trial. The Supreme Court affirmed, holding that the circuit court did not commit reversible error when it refused Plaintiff’s requested instructions because Plaintiff’s evidence left room for different presumptions or inferences negating the applicability of the doctrine. View "Steilen v. Cabela’s Wholesale, Inc." on Justia Law

The Supreme Court reversed the circuit court’s order rejecting the plea agreement between Defendant and the State.After Defendant and the State entered into a plea agreement the circuit court accepted Defendant’s guilty plea and the factual basis to support the plea. Two weeks later, the circuit court informed the parties that it intended to reject the plea agreement. The court then entered an order rejecting the plea agreement. Defendant appealed, arguing that the circuit court was bound by the plea agreement. The Supreme Court agreed, holding that because the circuit court at the time of the plea did not reject the agreement and did not defer its decision to accept or reject the agreement, the circuit court was required to sentence Defendant within the bounds of the plea agreement. The court remanded the case with directions to sentence Defendant in accordance with the agreement. View "State v. Hale" on Justia Law

The Supreme Court reversed the circuit court’s order rejecting the plea agreement between Defendant and the State.After Defendant and the State entered into a plea agreement the circuit court accepted Defendant’s guilty plea and the factual basis to support the plea. Two weeks later, the circuit court informed the parties that it intended to reject the plea agreement. The court then entered an order rejecting the plea agreement. Defendant appealed, arguing that the circuit court was bound by the plea agreement. The Supreme Court agreed, holding that because the circuit court at the time of the plea did not reject the agreement and did not defer its decision to accept or reject the agreement, the circuit court was required to sentence Defendant within the bounds of the plea agreement. The court remanded the case with directions to sentence Defendant in accordance with the agreement. View "State v. Hale" on Justia Law