Justia South Dakota Supreme Court Opinion Summaries

The case involves Wesley Castle's petition to adopt his stepchildren, I.V.E., C.A.E., and L.A.E. The children's biological father and ex-husband of Wesley's wife, Isaac Ellsaesser, objected to the petition, arguing that he does not consent to the adoption and that his consent cannot be waived under SDCL 25-6-4. The children's mother, Frances, had previously divorced Isaac due to a toxic and abusive relationship. Isaac had struggled with alcohol addiction and had faced domestic abuse charges. After the divorce, Isaac completed treatment for his addiction and attempted to reestablish a relationship with his children.The Circuit Court of the Fourth Judicial Circuit in Lawrence County, South Dakota, held an evidentiary hearing on whether Isaac’s consent could be waived. The court determined that Wesley did not prove any of the statutory grounds for waiver by clear and convincing evidence. The court entered an order denying Wesley’s petition, and Wesley appealed to the Supreme Court of the State of South Dakota.The Supreme Court of the State of South Dakota affirmed the lower court's decision. The court found that Wesley failed to establish by clear and convincing evidence that Isaac had substantially and continuously neglected his children or willfully neglected to pay child support. The court noted that Isaac had made several concerted efforts to reestablish a parental relationship with his children and had begun making child support payments after determining the amount he owed in arrears and how to pay. The court concluded that Isaac's failure to pay child support could not be considered willful under the circumstances. View "In the Matter of the Adoption of I.V.E." on Justia Law

Brandon Hahn was convicted by a jury for intentional damage to property, with the damage amount totaling more than $1,000 but less than $2,500. The property in question was the front door of 88-year-old Delores Moen's home, which Hahn was accused of damaging. Hahn was also charged with obstructing a public officer and disorderly conduct, the latter of which was later dismissed. The State presented multiple witnesses, including Delores' neighbors and the responding police officers, who testified about Hahn's aggressive conduct and their interactions with him. Hahn himself denied any responsibility for damaging the door.In the Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, Hahn moved for judgment of acquittal on the intentional damage to property charge, arguing that the State had not established the fair market value of the door, which he claimed included depreciation. The court denied his motion, concluding that the State could prove the damage amount element through evidence of the cost of reasonable repairs. Hahn was found guilty on both counts and was sentenced to an enhanced 15-year prison sentence on Count 1 with ten years suspended and a 30-day jail sentence on Count 2.In the Supreme Court of the State of South Dakota, Hahn appealed, claiming that the circuit court erred when it denied his motion for judgment of acquittal on the intentional damage to property charge. He argued that the jury could not properly apply the damage element without first establishing the fair market value of the property. The Supreme Court disagreed, stating that the current version of the intentional damage to property statute focuses on the "damage to property" and not the value of the property. The court concluded that there was sufficient evidence for the jury to find that the damage Hahn caused to Delores’ door was at least $1,000 but less than $2,500, and affirmed the circuit court's decision. View "State v. Hahn" on Justia Law

The case involves Melissa Palmer, who applied for Pandemic Unemployment Assistance (PUA) benefits due to loss of income from her self-employment as a sign-language interpreter during the COVID-19 pandemic. Despite continuing to work her second job at Woofs and Waves, she did not report this income in her weekly requests for benefits. The South Dakota Department of Labor and Regulation, Reemployment Assistance Division (Department) determined that she had misrepresented her income and was therefore ineligible for the benefits she had received. The Department ordered her to repay the benefits and assessed a mandatory penalty.The administrative law judge (ALJ) upheld the Department's decision, finding that Palmer had willfully misrepresented her income. The circuit court affirmed the ALJ’s decision. Palmer appealed, arguing that she had not willfully misrepresented her income because she believed she only needed to report her self-employment income.The Supreme Court of the State of South Dakota reversed the lower courts' decisions. The Court found that the ALJ's finding that Palmer believed she only needed to report her self-employment income was inconsistent with the conclusion that she had willfully misrepresented her income. The Court held that a willful misrepresentation requires evidence of intentional misrepresentation, not merely knowledge of the falsity of the representation. The Court remanded the case for the ALJ to reconsider whether Palmer was at fault for the overpayment and whether she was eligible for a waiver. View "Palmer V. Dep’t Of Labor & Regulation" on Justia Law

Miranda Ann Henry, also known as Crystal Trinity Pumpkinseed, was sentenced to 75 years for first-degree manslaughter for the death of her boyfriend, Christopher Mexican. Henry had been released from prison on parole after serving 13 months for her fourth DUI conviction. She returned to Pierre to continue her relationship with Mexican and began using alcohol and methamphetamine. On February 8, 2022, after a week of heavy drinking, Henry decided to stop drinking. However, she began experiencing hallucinations, a condition she had suffered from since 2014. On February 9, 2022, Henry woke up next to Mexican's lifeless body, covered in blood. Law enforcement found a bloody box cutter in Henry's pocket and her blood alcohol content was 0.227%.Henry was indicted for second-degree murder. However, she entered into a plea agreement, pleading guilty to first-degree manslaughter involving domestic abuse. The State dismissed the second-degree murder charge. At the sentencing hearing, the court considered Henry's character and history, including her age, previous felony convictions, problems with alcohol abuse, and mental health issues. The court also considered the gruesome nature of the crime and the fact that Henry did not attempt to hide from law enforcement. The court sentenced Henry to 75 years with credit for time served.Henry appealed, arguing that the court abused its discretion in sentencing. She claimed that the court failed to properly weigh certain circumstances, including her unstable history, nonviolent criminal history, history with alcohol abuse, her intoxication at the time of the offense, and her mental state at the time of the offense. The Supreme Court of the State of South Dakota affirmed the lower court's decision, stating that the court did not abuse its discretion in sentencing Henry. The court had considered an extensive presentence investigation report and determined that, based on the heinousness of the offense, her prior opportunities for treatment, and her demonstrated tendency to keep committing crimes, she deserved a 75-year sentence. View "State v. Henry" on Justia Law

The case involves MRose Development Co., LLC and Jason Schumacher (MRose) who sought to develop farmland located along Swan Lake in Turner County into 15 lakefront lots. The land was currently included in an agricultural zoning district, and due to residential density restrictions, MRose applied to rezone the land into a lake residential district. The Turner County Board of County Commissioners (the County) denied the application, and MRose appealed to the circuit court.The circuit court reversed the County's decision, interpreting Turner County's zoning ordinance to require approval of the rezoning application as a purely ministerial act because the land was situated along Swan Lake. The County appealed this decision.The Supreme Court of the State of South Dakota reversed the circuit court's decision. The court found that the circuit court erred in its interpretation of the 2008 Zoning Ordinance, which it believed required the County to approve MRose's rezoning application. The Supreme Court held that no provision in the entire 2008 Zoning Ordinance stated that lakefront property must be zoned Lake Residential simply by virtue of its location. The court also held that the County's decision to deny MRose's rezoning application was not arbitrary, as MRose failed to meet its burden of proof that the County acted arbitrarily. View "Mrose Development Co. v. Turner County Bd. Of Commissioners" on Justia Law

The case involves J and L Farms, Inc. (J&L), a South Dakota company, and First Bank, a Florida banking corporation. J&L had an ongoing business relationship with Jackman Wagyu Beef, LLC (Jackman), a Florida-registered company, where Jackman would purchase cattle from J&L. In 2018, Jackman proposed a change in their payment terms, offering to pay for the cattle within 30 days of placing an order, instead of paying prior to the cattle being shipped. To secure each payment, Jackman proposed that J&L would be given a bank guarantee from First Bank. First Bank issued three separate guaranty letters to J&L to secure payment for the sale of cattle. However, Jackman failed to provide full payment for two orders, and First Bank refused to satisfy the outstanding balance.The circuit court of the Fifth Judicial Circuit in Brown County, South Dakota, entered a default judgment against Jackman after it failed to plead or defend against J&L’s complaint. First Bank filed a motion to dismiss for lack of personal jurisdiction, arguing that it did not have sufficient minimum contacts for a South Dakota court to exercise personal jurisdiction over it. The circuit court denied the motion.The Supreme Court of the State of South Dakota affirmed the circuit court's decision. The Supreme Court found that First Bank had sufficient minimum contacts with South Dakota to establish personal jurisdiction. The court reasoned that First Bank purposefully availed itself of the privileges of acting in South Dakota by issuing three guaranty letters to J&L, a South Dakota company, to facilitate the purchase of South Dakota cattle. The court also found that the cause of action against First Bank arose from its activities directed at South Dakota, and that the acts of First Bank had a substantial connection with South Dakota, making the exercise of jurisdiction over First Bank reasonable. View "J&l Farms" on Justia Law

Brandon Scott was convicted of grand theft, a Class 5 felony, after he pled guilty to stealing a Ford F-350 pickup. The theft was part of a series of events that included breaking into a store and damaging property. Scott and the State had reached a plea agreement, which included a recommendation for a four-year "cap" at sentencing. However, the circuit court sentenced Scott to a six-year prison term with three years suspended, which Scott argued violated the terms of the plea agreement.The Circuit Court of the Second Judicial Circuit in Lincoln County, South Dakota, had initially heard the case. The court accepted Scott's guilty plea and moved on to sentencing. During the sentencing hearing, Scott's counsel requested a fully suspended prison sentence concurrent with the sentence Scott was already serving. The State, however, urged the court to impose a four-year penitentiary sentence, coupled with additional suspended time. The court ultimately imposed a six-year prison sentence with three years suspended.Upon appeal, the Supreme Court of the State of South Dakota affirmed in part, but vacated and remanded for resentencing due to the circuit court's noncompliance with SDCL 22-6-11, a statute that requires a court to sentence criminal defendants convicted of a Class 5 felony to a term of probation or a fully suspended penitentiary sentence, unless there are aggravating circumstances. The Supreme Court found that the circuit court did not err in considering itself not bound by the parties' plea agreement, nor did it err in finding there was a sufficient factual basis to support Scott's plea. However, the court did not apply the provisions of SDCL 22-6-11 during sentencing, which constituted error. View "State V. Scott" on Justia Law

The case involves James Joseph Lanpher, Jr., who pleaded guilty to two counts of aggravated assault against a law enforcement officer and admitted to being a habitual offender. The charges stemmed from a dangerous high-speed chase during which Lanpher repeatedly fired weapons at pursuing officers. The circuit court sentenced Lanpher to serve two concurrent life sentences to run consecutively to sentences he was already serving for other offenses. Lanpher appealed, claiming his sentence was cruel and unusual in violation of the Eighth Amendment and was an abuse of the circuit court’s discretion.The case was previously reviewed by the circuit court of the Third Judicial Circuit, Lake County, South Dakota. The court found Lanpher guilty and sentenced him to two concurrent life sentences, to be served consecutively to sentences he was already serving for other offenses.The Supreme Court of the State of South Dakota reviewed the case and affirmed the decision of the lower court. The court found that Lanpher's sentence did not constitute cruel and unusual punishment in violation of the Eighth Amendment. The court also found that the circuit court did not abuse its discretion in the imposition of Lanpher’s sentence. The court noted that Lanpher's violent criminal history and demonstrated disregard for human life justified the severity of his sentence. View "State v. Lanpher" on Justia Law

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