Justia South Dakota Supreme Court Opinion Summaries

A Mexican national, J.R., who worked seasonally in Sully County, South Dakota, required emergency medical treatment for appendicitis. He was taken to Avera St. Mary’s Hospital in Hughes County, where he received treatment and incurred medical bills totaling over $75,000. J.R. had no health insurance, few assets, and returned to Mexico without paying the bills. Avera sought reimbursement from Sully County under county poor-relief statutes.The Sully County Board of Commissioners denied Avera's application for reimbursement, citing J.R.'s status as a nonresident of Sully County. Avera appealed this decision to the circuit court, which remanded the case back to the Commission for a more detailed factual record. After a hearing, the Commission again denied Avera's claim, determining that J.R. was indigent by design and was not in distress in Sully County at the time the county was notified. Avera appealed this decision to the circuit court, which affirmed the Commission's decision.The Supreme Court of the State of South Dakota affirmed the lower court's decision. The court found that the county's obligation to support poor persons is statutory, not common law. The court interpreted the poor-relief statutes to require every county to support all poor and indigent persons who have established residency therein. However, the parties agreed that J.R. was not a resident of Sully County. The court found that the county had no statutory obligation to reimburse Avera for J.R.'s emergency medical services, as he was a nonresident indigent who had left Sully County before the Commission learned he was in distress. The court concluded that in these circumstances, where temporary relief had already been administered to the nonresident indigent by a third party in another county, Sully County had no statutory obligation to reimburse Avera for J.R.'s emergency medical services. View "Avera St. Mary’s Hospital V. Sully County" on Justia Law

The case involves Scotlynn Transport, LLC and Plains Towing and Recovery, LLC, disputing the ownership of a semi-tractor. The semi-tractor, owned by Scotlynn, was involved in an accident and subsequently towed by Plains Towing to its impound lot. After Scotlynn paid for the towing services and took possession of the trailer, the semi-tractor remained at the impound lot. Plains Towing, considered a "removal agency" under South Dakota law, sent a notice to Scotlynn and later acquired the title to the semi-tractor using the statutory procedure outlined in SDCL 32-36-8 and 32-36-9. Scotlynn initiated a lawsuit against Plains Towing, alleging several claims related to the disputed ownership of the semi-tractor.The Circuit Court of the Fourth Judicial Circuit, Meade County, South Dakota, granted Plains Towing's motion for summary judgment, concluding that Plains Towing had complied with SDCL 32-36-8 and lawfully obtained the title to the semi-tractor. Scotlynn appealed, arguing that there were genuine issues of material fact relating to claims raised in Scotlynn’s complaint that were not addressed by the court.The Supreme Court of the State of South Dakota partially reversed and affirmed the lower court's decision. The court found that there were genuine issues of material fact concerning the existence of an implied contract between the parties regarding the storage of the tractor. However, the court agreed with the lower court that the "drafting errors" Scotlynn alleged were contained in the notice would not, themselves, preclude obtaining the title under SDCL 32-36-9. The case was remanded for further proceedings consistent with the court's holdings. View "Scotlynn Transport, LLC v. Plains Towing and Recovery, LLC" on Justia Law

In October 2019, Max Bolden shot and killed Benjamin Donahue outside a club in Sioux Falls, South Dakota. Bolden was indicted for first-degree murder, second-degree murder, and possession of a firearm by a convicted felon. At trial, Bolden claimed that he shot Donahue in self-defense. The circuit court denied Bolden's motions for a judgment of acquittal on the murder charges. The jury found Bolden guilty of first-degree murder and possession of a firearm by a convicted felon. Bolden appealed his first-degree murder conviction on the grounds of insufficient evidence.The Supreme Court of the State of South Dakota affirmed the lower court's decision. The court found that there was sufficient evidence to support the jury's verdict. The court noted that Bolden had used a gun to shoot Donahue point blank in the face without provocation, and then shot him again while he was lying on the ground. The court also pointed out that Bolden had immediately left the scene, fled the state, and disposed of the gun used to shoot Donahue. The court concluded that a rational trier of fact could have found the essential elements of first-degree murder beyond a reasonable doubt. View "State v. Bolden" on Justia Law

The case revolves around a dispute over the estate of Neil Smeenk. Denise Schipke-Smeenk, Neil's wife, and Ryan Smeenk, Neil's son, are the parties involved. Denise and Neil had executed mutual and reciprocal wills in 2017, along with an agreement that neither would revoke or amend their wills without the other's written consent. However, after their relationship deteriorated, Neil executed a new will without Denise's consent, disinheriting her to the extent allowed under South Dakota law and naming his children as the primary beneficiaries. Neil passed away shortly after. Denise filed a petition for formal, unsupervised probate concerning the 2017 will, and Ryan filed a competing petition to probate the 2019 will.The circuit court determined that Neil's 2019 will was valid and should be admitted into probate. The court concluded that the couple's agreement did not render Neil's 2017 will irrevocable, though it may subject his estate to liability. Denise later filed a motion for approval of a creditor claim in which she proposed to distribute Neil's estate according to the terms of his 2017 will. The circuit court conducted a court trial regarding Denise’s claim, but ultimately denied Denise’s claim, stating that Denise did not demonstrate that the circumstances supported the equitable remedy of specific performance.In the Supreme Court of the State of South Dakota, Denise appealed the circuit court's decision. The Supreme Court affirmed the circuit court’s decision to deny Denise’s claim after a court trial. Denise then filed a motion for partial summary judgment relating to her breach of contract claim against the estate of her deceased husband, Neil Smeenk. She changed the type of relief she was requesting; she was now seeking money damages for the breach instead of the specific performance remedy she had pursued unsuccessfully in the previous case. However, the circuit court concluded that Denise was barred from litigating her breach of contract claim against Neil’s estate. Denise appealed this decision, but the Supreme Court affirmed the circuit court's decision, stating that Denise had a complete and fair opportunity to litigate her breach of contract claim in the prior proceeding. View "Estate Of Smeenk" on Justia Law

Lonnie Reidburn, a self-employed insurance agent, appealed a decision by the South Dakota Department of Labor, Reemployment Assistance Division (Department) that he must repay $24,690 in pandemic unemployment benefits he received. Reidburn's income was based on commissions he received for new policies and renewals, which required in-person visits to clients' homes or businesses. During the COVID-19 pandemic, Reidburn experienced a significant reduction in his ability to procure new policies and renewals because clients did not want him to make in-person visits. As a result, Reidburn's income decreased. He applied for Pandemic Unemployment Assistance (PUA) through the Department and received benefits for 39 weeks. However, the Department later determined that Reidburn's loss of income was not the direct result of the pandemic and issued a determination of ineligibility.The administrative law judge (ALJ) upheld the Department's determination of ineligibility, reasoning that the individual decisions of Reidburn's clients to preclude him from entering their homes or places of business were not a direct result of the pandemic. However, the ALJ rejected the Department's at-fault determination and found that Reidburn was not at fault for the overpayment. The ALJ also concluded that Reidburn's request for a waiver was untimely. Reidburn appealed the ALJ's decision to the circuit court, which affirmed the ALJ's decision.The Supreme Court of the State of South Dakota reversed the ALJ's determination that Reidburn was ineligible to receive PUA benefits for 35 of the 39 weeks at issue, based on its recent decision in Bracken v. South Dakota Department of Labor and Regulation, Reemployment Assistance Division. The court declined to address the Department's argument that Reidburn failed to present sufficient evidence to support his testimony that he experienced a significant reduction in services, as the Department did not raise this argument at Reidburn's administrative hearing. The court affirmed the circuit court's denial of Reidburn's motion for attorney fees. View "Reidburn v. Department of Labor & Regulation" on Justia Law

The case involves a dispute over the will of Dennis Schmeling, who left his farmland to his sister-in-law, Sharon, in his 2021 will. Two of Dennis's brothers and one nephew contested the will, alleging undue influence by Sharon. The Estate moved for summary judgment, arguing that the contestants could not show that the devise was the result of undue influence, based on a previous court decision (In re Estate of Tank). The circuit court agreed with the Estate, concluding that there was no evidence showing that Dennis had a testamentary disposition toward the contestants and that the contestants did not present evidence showing that Sharon participated in the drafting of the disputed will or engaged in acts of undue influence. The contestants appealed this decision.The Supreme Court of the State of South Dakota reversed the circuit court's decision and remanded the case. The Supreme Court found that the circuit court had erred by granting summary judgment on grounds not raised by the parties and by granting the Estate's motion for summary judgment. The Supreme Court concluded that there were material issues of fact in dispute on the contestants' claim that the 2021 Will was the result of Sharon’s undue influence. Therefore, the circuit court erred in granting the Estate’s motion for summary judgment. The Supreme Court also found that the circuit court erred in denying the contestants' partial motion for summary judgment, as it was undisputed that neither the 2002 Will nor the 2021 Will contains language expressly disinheriting the contestants. View "In re Estate Of Schmeling" on Justia Law

Tristen Simonsen was convicted on two counts of solicitation of a minor, one count of sexual contact with a minor under the age of sixteen, and one count of rape in the fourth degree. The court did not specify during sentencing whether it intended to treat each charge as a separate transaction. After sentencing, the court signed four separate judgments of conviction and ordered each conviction to be served consecutively. Later the same day, the court held a hearing to clarify its intent, determining that each charge was the result of a separate transaction. Simonsen appealed, arguing that the court improperly enhanced his sentence after it had already commenced.The Supreme Court of South Dakota disagreed, ruling that the circuit court's post-sentencing declaration to treat each charge as a separate transaction only affected Simonsen's future eligibility for parole, not his sentence. The court also rejected Simonsen's argument that his constitutional rights were violated by his absence from the post-sentencing hearing, noting that the hearing only impacted his parole eligibility. The Supreme Court affirmed the circuit court's decision. View "State V. Simonsen" on Justia Law

Matthew Feucht was found guilty of possession of a controlled substance and was sentenced to nine years in prison with four years suspended. The case arose when Feucht's daughter discovered bags of marijuana in their home and alerted her mother, who then contacted the police. A search warrant was executed, leading to the discovery of firearms, ammunition, drug paraphernalia, and approximately $6,800 in small bills. Feucht was subsequently indicted on multiple charges, but under a plea agreement, he pled guilty to unauthorized possession of a controlled substance.The Circuit Court of the Second Judicial Circuit in Lincoln County, South Dakota, accepted Feucht's guilty plea and sentenced him to nine years in prison with four years suspended. Feucht appealed the sentence, arguing that the circuit court erred by imposing a penitentiary sentence without finding aggravating circumstances within the meaning of SDCL 22-6-11 and by not listing the aggravating circumstances in the judgment of conviction.The Supreme Court of the State of South Dakota agreed with Feucht's argument. The court found that the circuit court did not clearly identify on the record that it was departing from presumptive probation based on the existence of aggravating circumstances posing a significant risk to the public. Therefore, the Supreme Court vacated Feucht's sentence and remanded the case for a new sentencing hearing. View "State V. Feucht" on Justia Law

Paul Trueblood was charged with multiple offenses, including second-degree rape, following a sexual encounter with D.B.L. After a mistrial due to D.B.L. contracting COVID-19, the State presented additional evidence to a grand jury, which added charges of aiding and abetting, witness tampering, and solicitation of witness tampering. These charges were based on allegations that Trueblood arranged to have D.B.L. attacked to prevent her from testifying. On the morning of the second trial, Trueblood pled guilty to second-degree rape under a plea agreement with the State, which dismissed all other charges.Trueblood later filed a motion to withdraw his guilty plea, asserting his innocence but acknowledging that he did not immediately stop the sexual act when D.B.L. withdrew her consent. The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, denied the motion, finding that Trueblood's plea was entered knowingly and voluntarily and that he had not established any "fair and just reason" for the withdrawal.The Supreme Court of the State of South Dakota affirmed the lower court's decision. The court found that Trueblood's fear of the possible ramifications of a trial was not a sufficient reason to withdraw his guilty plea. The court also noted that Trueblood's motion was not premised on a claim of actual innocence, as he continued to admit to facts sufficient for second-degree rape. The court concluded that the lower court did not abuse its discretion by denying Trueblood’s motion to withdraw his guilty plea. View "State V. Trueblood" on Justia Law

The case involves Keaton Van Der Weide, who was accused of raping S.O., his on-and-off partner and mother of his child. S.O. alleged that Van Der Weide sexually assaulted her after she returned home from a night out, while Van Der Weide maintained that the encounter was consensual and involved the use of sex toys. He was charged with second-degree rape.Before trial, Van Der Weide sought to introduce evidence of the sex toys and text messages between himself and S.O. The circuit court ruled that unless the State alleged that a toy was used during the rape, Van Der Weide could not proffer evidence of the same. The court allowed the State to cross-examine Van Der Weide based on other texts surrounding the excerpted messages. Van Der Weide was found guilty and appealed, arguing that the court abused its discretion in excluding evidence of the sex toys and allowing the State to cross-examine based on unadmitted text messages.The Supreme Court of the State of South Dakota reversed the decision, finding that the circuit court had erred in excluding Van Der Weide's testimony regarding the sex toys, violating his constitutional right to testify in his defense. The court could not conclude that preventing the jury from weighing this important context was harmless beyond a reasonable doubt. Therefore, Van Der Weide was entitled to a new trial. View "State v. Van Der Weide" on Justia Law