Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed the circuit court’s dismissal of Plaintiff’s personal injury action as a sanction for Plaintiff’s failure to comply with two discovery orders and failure to pay an attorney’s fees sanction for her failure to comply with a motion to compel discovery. The court held that the circuit court (1) did not err in granting Defendant’s motion for a sanction of attorney’s fees against Plaintiff for her failure to produce documents; (2) did not err in dismissing Plaintiff’s complaint as a sanction for failing to produce IRS Form W-2s; and (3) did not err in dismissing Plaintiff’s complaint as a sanction for failure to pay the attorney’s fees sanction. View "Coloni v. Coloni" on Justia Law

The Supreme Court affirmed Defendant’s conviction for unlawfully possessing a controlled substance, holding that the evidence was sufficient to prove that Defendant knowingly possessed oxycodone, a controlled drug. At issue on appeal was whether the evidence was sufficient to prove that Defendant knew the pills he possessed were a controlled substance of some kind. The Supreme Court held that, when viewed cumulatively and taken in a light most favorable to the jury’s verdict, there was sufficient evidence and inferences therefrom for a rational jury to have found that Defendant knew the pills he possessed were a controlled substance. View "State v. Martin" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Mother and Stepfather’s (together, Petitioners) petition to have Stepfather adopt Mother’s child without the biological father’s (Father) consent. Petitioners contended that Father’s consent was unnecessary because, among other things, Father had abandoned the child. The circuit court concluded that Petitioners failed to prove by clear and convincing evidence that that Father had abandoned the child. The Supreme Court agreed, holding that the circuit court did not err in determining that Petitioners failed to show by clear and convincing evidence that Father had given up or totally deserted the child. View "In re Adoption of J.Q.P." on Justia Law

The Supreme Court reversed a circuit court order approving the redrafting of Dean Nelson’s will. The change in the will was proposed upon the petition of Dean’s conservator after Dean was diagnosed with Alzheimer’s disease. Elizabeth Nelson, Dean’s wife, argued on appeal that the circuit court erred in permitting the conservator to adopt the new will, which eliminated a trust established for Elizabeth’s benefit consisting of Elizabeth’s lifetime, one-half interest in the residue of Dean’s estate. The Supreme Court agreed, holding that the circuit court’s decision to authorize the conservator to change the will was an abuse of discretion due to the lack of adequate factual findings. View "In re Guardianship of Nelson" on Justia Law

The Supreme Court affirmed the determination of the circuit court finding that Plaintiffs ido not have an easement, either by grant or prescription, across Mineral Survey 1758 (M.S. 1758) into the adjoining Mineral Survey 1794. On appeal, Plaintiffs asserted that a public right-of-way existed across M.S. 1758 by grant but did not appeal the denial of a prescriptive easement. In affirming, the Supreme Court held that Plaintiffs failed to establish a right in the disputed road that traverses M.S. 1758 by grant in deeds or by statute, and therefore, the circuit court did not err in determining that the disputed road is private. View "Chicoine v. Davis" on Justia Law

The Supreme Court affirmed Defendant’s termination from the drug-court program and subsequent revocation of suspension of execution of a four-year sentence. Contrary to Defendant’s arguments raised on appeal, the Supreme Court held (1) this court may not directly review the drug court’s actions in this appeal, but the court does have appellate jurisdiction over the circuit court’s decision to revoke the suspension of execution of Defendant’s sentence; and (2) the circuit court did not abuse its discretion by revoking the suspension of execution of Defendant’s sentence and by reinstating her original, four-year sentence. View "State v. Stenstrom" on Justia Law

The Supreme Court affirmed Defendant’s convictions of first-degree robbery and possession of a firearm by a convicted felon. Contrary to Defendant’s arguments on appeal, the court held (1) the State’s evidence was sufficient to corroborate accomplice testimony, and therefore, the circuit court did not err in denying Defendant’s motion for a judgment of acquittal; (2) even if the circuit court’s admission into evidence several challenged evidentiary items was in error, the error was harmless; (3) the circuit court did not violate Defendant’s right to confront and examine a witness whose out-of-court statements were admitted at trial; and (4) the circuit court did not abuse its discretion in imposing Defendant’s sentence. View "State v. Kihega" on Justia Law

The Supreme Court reversed the circuit court’s determination that a confidential settlement agreement entered into between the City of Sioux Falls and several contractors that built the Denny Sanford Premier Center in Sioux Falls was not open to public inspection under S.D. Codified Laws 1-27. A reporter for the Argus Leader sought a copy of the agreement. After the City denied the request the Argus Leader commenced this action seeing an order compelling the City to provide a copy. The circuit court entered judgment for the City. The Supreme Court reversed, holding that the settlement contract at issue did not meet the requirements under section 1-27-1.5(20), and therefore, it is a public record open to inspection. View "Argus Leader Media v. Hogstad" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Defendant’s motion to suppress evidence discovered after police officers executed a search warrant at Defendant’s home. During the search, officers found marijuana in Defendant’s van, which was parked outside the home. The circuit court ruled (1) Defendant did not have a personal, legitimate expectation of privacy in his friend’s home and therefore could not challenge the search; and (2) alternatively, the search did not violate Defendant’s Fourth Amendment rights. The Supreme Court affirmed, holding that the circuit court did not err when it denied Defendant’s motion to suppress because Defendant did not establish a protectable interest in the property searched. View "State v. Gaters" on Justia Law

The Supreme Court affirmed in part and reversed in part the denial of the circuit court’s motion to suppress the evidence obtained after law enforcement officers executed a search warrant for Defendant’s home and arrested Defendant. The officers obtained the warrant based on information gained from a pole camera installed without a warrant on a public street light to record Defendant’s activities outside of his home. On appeal, Defendant argued that the officers’ use of the pole camera without a warrant violated the Fourth Amendment. The Supreme Court held (1) the warrantless use of the pole camera, installed to observe Defendant’s activities outside his residence for a two-month period, constituted a search under the Fourth Amendment, and therefore, the officer that installed the camera was required to first obtain a warrant; but (2) the officer acted reasonably based on the facts of this case, and the circuit court did not err when it denied Defendant’s motion to suppress based on the good faith exception to the exclusionary rule. View "State v. Jones" on Justia Law