Justia South Dakota Supreme Court Opinion Summaries

Appellant Merle Temple and Appellee Bradley Gartner owned 3,375 acres of land as tenants in common. After relations between Temple and Gartner deteriorated, Gartner brought an action for partition. After appointing three referees and adopting the referees’ report, the circuit court ordered a partition in kind and ordered Gartner to make a compensatory payment to Temple. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in ordering a partition in kind, as Temple did not show that partition in kind would cause great prejudice to the owners; (2) the circuit court did not err in adopting the referees’ report; and (3) the circuit court did not err in refusing to reduce the compensatory payment in favor of allocating additional land to Temple. View "Gartner v. Temple" on Justia Law

Eastern Farmers Cooperative (EFC) applied for and was granted a conditional use permit to build and operate an agronomy facility on sixty acres of land near Colton, South Dakota. Appellants’ residence was directly across a county road from the proposed facility. Appellants appealed. The Minnehaha County Commission upheld the decision to grant the conditional use permit to EFC, as did the circuit court. The Supreme Court affirmed, holding (1) the County Commission’s decision to uphold the approval of the permit was not arbitrary and capricious in violation of Appellants’ due process rights; and (2) any alleged due process concerns arising out of a certain commissioner’s participation in the County Commission’s action were remedied by invalidating that commissioner’s vote. View "Hanson v. Minnehaha County Comm'n" on Justia Law

Appellant filed claims of legal malpractice and breach of fiduciary duty against his former attorneys (Appellees) based on an alleged conflict of interest relating to Appellees’ representation of his co-defendants in an underlying lawsuit. The circuit court granted summary judgment for Appellees and dismissed Appellant’s claims. The Supreme Court held that summary judgment was improper. Specifically, the Court held that the circuit court (1) erred in striking Appellant’s expert opinion; (2) did not err by finding collateral estoppel precluded litigation of the limited issue of whether Hamilton signed a conflict of interest waiver; and (3) improperly weighed evidence in granting summary judgment regarding proximate cause. Remanded. View "Hamilton v. Sommers" on Justia Law

After a jury trial, Defendant was convicted of rape and two counts of aggravated assault and sentenced to ten years in prison on each count, to be served concurrently. The Supreme Court affirmed, holding (1) the circuit court did not commit structural error by allowing the State’s reasonable doubt standard to be presented to the jurors during voir dire; (2) the State’s questioning during voir dire amounted to plain error, but Defendant’s substantial rights were not impacted by the prosecutor’s improper comments; and (3) the evidence was sufficient to support Defendant’s convictions, and therefore, the circuit court did not err in denying Defendant’s motion for judgment of acquittal. View "State v. Hayes" on Justia Law

Petitioner pleaded guilty to manslaughter in the first degree. Petitioner subsequently filed a motion to withdraw his guilty plea, which the circuit court denied. The Supreme Court affirmed the denial. Thereafter, Petitioner filed an amended and second amended application for a writ of habeas corpus, claiming that his due process rights were violated and that he was denied the right to effective assistance of counsel. The habeas court denied relief. The Supreme Court affirmed, holding (1) Petitioner’s guilty plea was voluntary and intelligent; (2) the circuit court did not abuse its discretion when it denied Petitioner’s motion to withdraw his guilty plea; and (3) Petitioner was not denied effective assistance of counsel. View "LeGrand v. Weber" on Justia Law

A.H. Meyer & Sons, Inc. produced honey and beeswax at a plant in Winfred, South Dakota. Barton Solvents, Inc. sold the heptane to A.H. Meyer that A.H. Meyer used in its beeswax rendering process. The heptane was manufactured by CITGO Petroleum Corporation. In 2009, A.H. Meyer suffered a heptane explosion at its plant. Nationwide Mutual Insurance paid for the damage. Nationwide subsequently filed suit seeking subrogation from Barton Solvents and CITGO on causes of action alleging strict liability, negligence, and breach of express and implied warranties. All theories were premised on the theory that Defendants failed adequately to warn of heptane’s dangers. The circuit court granted summary judgment for Defendants. The Supreme Court affirmed, holding that summary judgment was appropriate because no material issues of disputed fact existed with respect to the adequacy of the warnings. View "Nationwide Mut. Ins. Co. v. Barton Solvents, Inc." on Justia Law

Atlas Hydraulics, Inc. constructed an addition to its manufacturing plant on the side of its existing building that abutted residential property owned by Sherri Strong. After years of enduring water flow from the Atlas property onto her property, Strong sued Atlas for nuisance, negligence, and negligence per se and also filed a motion for preliminary and permanent injunctions. The circuit court granted both the preliminary and permanent injunctions prohibiting Atlas from allowing surface water to uncontrollably discharge onto Strong’s property in a manner that would threaten Strong’s property and residential structure. The Supreme Court affirmed, holding primarily that the circuit court did not misapply the relevant statutes and case law in granting an injunction regarding ground water nuisance. View "Strong v. Atlas Hydraulics, Inc." on Justia Law

Defendant was convicted of first-degree arson and first-degree felony murder for intentionally setting fire to an occupied structure, resulting in the death of an unidentified victim in the fire. Defendant was sentenced to concurrent life sentences without parole for each conviction. Defendant filed a motion to correct an illegal sentence, claiming that the concurrent sentences violated the constitutional prohibition against double jeopardy. The circuit court denied Defendant’s motion. The Supreme Court affirmed, holding that the Legislature intended to authorize cumulative punishment for violations of felony murder and the underlying felony of arson, and therefore, the circuit court was authorized by the Legislature to impose concurrent sentences for both crimes. View "State v. Garza" on Justia Law

Dr. Rueben C. Setliff, III filed a derivative action against several Managers individually and in their capacities as members of the management committee of Black Hills Surgical Physicians, LLC (BHSP), alleging that the Managers breached their fiduciary duties under BHSP’s operating agreement. The circuit court ruled that the dispute was subject to arbitration. The arbitrator ordered that Setliff recover attorney’s fees and costs against the Managers and ruled that the Managers were entitled to be indemnified by BHSP under the operating agreement. The circuit court concluded that the arbitrator did not exceed her authority in making the award of fees and costs and confirmed Setliff’s award. The Supreme Court reversed the circuit court’s order affirming the award, holding that the arbitrator exceeded her powers in awarding Setliff his attorney’s fees and expenses in direct violation of BHSP’s operating agreement. View "Black Hills Surgical Physicians v. Steliff" on Justia Law

Petitioner was found guilty of several sex-related crimes and sentenced to serve an aggregate sentence of 135 years. The Supreme Court affirmed the conviction on direct appeal. Petitioner subsequently applied for writ of habeas corpus. The circuit court dismissed the application, and Petitioner moved the Supreme Court for a certificate of probable cause (CPC) to appeal the circuit court’s denial of his application. The Supreme Court reversed the habeas court’s dismissal and remanded for an evidentiary hearing. After a hearing, the habeas court entered a final order denying Petitioner’s application and motion for a CPC. Petitioner subsequently filed a motion for a CPC with the Supreme Court seeking to appeal the habeas court’s final order denying relief. The Supreme Court denied Petitioner’s motion for issuance of a CPC, holding that because Petitioner failed to address the habeas court’s findings of fact and conclusions of law, he failed to make a substantial showing of the denial of a constitutional right and therefore failed to establish probable cause that an appealable issue existed for appellate review. View "Ashley v. Young" on Justia Law