Justia South Dakota Supreme Court Opinion Summaries

Defendant was indicted with one count of second-degree rape. During his trial, Defendant requested access to summaries written by the prosecutor or by others in the prosecutor’s office documenting the victim’s oral declarations about the alleged rape, claiming that the notes were discoverable under S.D. Codified Laws 23A-13-10(4). The trial court concluded that the prosecutor’s notes were protected attorney work product and did not fall under section 23A-13-10. The jury subsequently found Defendant guilty of rape. The Supreme Court reversed, holding that Defendant was entitled to have notes in the possession of the prosecutor containing summaries of the victim’s prior statements related to the allegations against Defendant produced for an in camera review by the circuit court to determine if those notes contain statements discoverable under section 23A-13-10(4). If the court concludes that the notes contain discoverable statements under section 23A-13-10 that could have affected the outcome of the trial, the court is directed to vacate Defendant’s conviction and order a new trial. View "State v. Horned Eagle" on Justia Law

This lawsuit centered around the termination of the employment of Dr. Sonia Hernandez by Avera Queen of Peace Hospital (Avera). Hernandez brought suit against Avera and multiple persons associated with the hospital for, inter alia, defamation and breach of contract. The circuit court dismissed several of Hernandez’s causes of action and, during the ensuing jury trial, entered judgment as a matter of law dismissing the defamation action. At the conclusion of the trial, the jury returned a verdict in favor of Avera on the breach of contract claim. The Supreme Court affirmed, holding that the circuit court did not err (1) when it dismissed several of Hernandez’s claims against Avera and the additional parties, and (2) when it dismissed Hernandez’s defamation claim during trial. View "Hernandez v. Avera Queen of Peace Hosp." on Justia Law

At issue in this dispute was property that consisted of a one-car garage and the land on which it sat. The dispute involved several properties, including Lot 8A, the property formerly owned by Rocky Mattson, who used and maintained the garage. Ron Underhill, the record owner of the other properties involved in this dispute, brought suit against Mattson, Mattson's wife, and Carmen Walton, the current record owner of Lot 8A, to quiet title to the disputed property. Underhill also sought damages and punitive damages on the ground that Walton’s use of the garage amounted to conversion. The trial court concluded that Walton had acquired the disputed property by adverse possession through her predecessors in interest and that Underhill’s conversion claim was moot. The Supreme Court affirmed, holding that the circuit court did not err in denying Underhill’s claims for quiet title and conversion. View "Underhill v. Mattson" on Justia Law

James Mordhorst was injured while working for Fischer Furniture. Almost one year later, Dakota Truck Underwriters and Risk Administration Services (collectively, Insurers) terminated all workers’ compensation benefits. The South Dakota Department of Labor subsequently ordered Insurers to pay all past medical bills and interest as well as future medial expenses. Mordhorst then filed an action seeking punitive damages for an alleged bad-faith denial of workers’ compensation benefits. The circuit court granted Insurers’ motion to dismiss for failure to state a cause of action upon which relief could be granted. The Supreme Court reversed, holding that the circuit court erred by granting Insurers’ motion to dismiss because Mordhorst asserted facts that, if true, state a claim for bad faith denial of a workers’ compensation claim and that Insurers’ reliance on an independent medical examiner’s report to deny benefits was not per se reasonable. View "Mordhorst v. Dakota Truck Underwriters" on Justia Law

Defendant pleaded guilty to possession of a controlled substance, a Class 5 felony, and admitted the allegations of a habitual criminal information alleging that she had two prior felony convictions. Because of Defendant’s prior convictions, the circuit court imposed a Class 4 felony penitentiary sentence. The court did not state on the record any aggravating circumstances justifying a departure from presumptive probation. Defendant appealed, arguing that the circuit court erred in failing to sentence her to probation pursuant to the presumptive probation requirements. The Supreme Court reversed and remanded for sentencing, holding that the circuit court erred when it failed to state the aggravating circumstances on the record or in the judgment. View "State v. Flowers" on Justia Law

Decedent named heirs in her will, but the heirs predeceased Decedent. Thus, Decedent’s estate became subject to the laws of intestate succession. The children of Decedent’s brother (collectively, Appellants) were designated as heirs of his estate. The circuit court then determined that the illegitimate daughter of Decedent’s brother (Yvette) was also an heir entitled to inherit equally from Decedent’s estate. In so holding, the circuit court concluded that S.C. Codified Laws 29A-2-114(c), which sets forth the methods under which an illegitimate child must establish paternity for purposes of intestate succession, was unconstitutional as applied to Yvette because it prohibited Yvette’s right to recover as an illegitimate child in violation of the Equal Protection Clause. The Supreme Court reversed, holding that, although section 29A-2-114(c) creates a classification between legitimate and illegitimate children, it is constitutional as applied to Yvette under both the federal and state constitutions. View "In re Estate of Flaws" on Justia Law

Decedent named heirs in her will, but the heirs predeceased Decedent. Thus, Decedent’s estate became subject to the laws of intestate succession. The children of Decedent’s brother (collectively, Appellants) were designated as heirs of his estate. The circuit court then determined that the illegitimate daughter of Decedent’s brother (Tamara) was also an heir entitled to inherit equally from Decedent’s estate. The Supreme Court affirmed, holding that the circuit court did not err by rendering a judgment of heirship declaring Tamara a biological child of Decedent’s brother and an equal heir with Appellants. View "In re Estate of Flaws" on Justia Law

After Charles Colombe died, Wesley Colombe filed a petition for informal probate and was appointed as personal representative of Charles’s Estate. The Rosebud Sioux Tribe (RST) filed a notice of creditor’s claim seeking to enforce a Rosebud Sioux Tribal Court order and judgment. Wesley filed a notice of disallowance of claim, asserting that the RST could not show that the order was entitled to comity. The circuit court granted comity to the tribal court order and judgment. The Supreme Court affirmed, holding that the circuit court did not err by granting comity to the tribal court order pursuant to S.D. Codified Laws 1-1-25. View "Rosebud Sioux Tribe v. Colombe" on Justia Law

Defendant was stopped by a police officer because his vehicle’s left brake light was not working. Defendant was subsequently arrested for driving under the influence of alcohol. Defendant filed a motion to suppress. The circuit court granted the motion, concluding (1) since the relevant statute required only two working brake lights Defendant did not violate the law because his vehicle’s right and top-center brake lights were working; and (2) the officer’s belief that South Dakota law required a working left and right brake light was objectively unreasonable. The Supreme Court reversed, holding (1) the most reasonable interpretation of the pertinent statute is that the Legislature intended the display and actuation requirements to apply only to two brake lights; but (2) it was objectively reasonable for an officer to believe that Defendant’s inoperative left brake light constituted a violation of law. View "State v. Lerma" on Justia Law

Westside Gilts RE, LLC submitted an application to the Beadle County Planning Commission for a conditional use permit (CUP) to construct and operate a concentrated animal feeding operation. The Planning Commission recommended approval of the CUP. The Beadle County Board of Adjustment (Board) approved the CUP. Petitioners appealed, arguing that the Board was without authority to issue the CUP because the county zoning ordinances passed in 2011 (Ordinances), which authorized the Board to grant the permit, were improperly enacted. The circuit court reversed the Board’s decision granting the CUP, concluding that the Ordinances were improperly enacted. The Supreme Court (1) affirmed the circuit court’s ruling reversing the Board’s decision to grant the CUP, holding that the Ordinances were invalid because the Planning Commission failed to comply with S.D. Codified Laws 11-2-18, and therefore, the Board lacked jurisdiction to grant a CUP; but (2) reversed the circuit court’s order declaring the Ordinances invalid, as the order exceeded the options available to the court under its limited scope of review on certiorari. View "Wedel v. Beadle County Comm’n" on Justia Law