Justia South Dakota Supreme Court Opinion Summaries

After a jury trial in 1995, Petitioner was convicted of child rape, sexual contact, disseminating harmful material to minors, and indecent exposure. Petitioner was acquitted in the same trial of raping two other children. Approximately a decade later, in a habeas corpus proceeding, the counseling records for the child Petitioner was convicted of raping were first disclosed. The habeas court denied Petitioner's amended petition for a writ of habeas corpus and Petitioner's amended motion for a certificate of probable cause, concluding that Petitioner had not shown "a reasonable probability that the specific timing of the disclosure would have created reasonable doubt in the jurors' minds considering the entire record." The Supreme Court issued a certificate of probable cause, resulting in this appeal. The Supreme Court affirmed, holding that Petitioner was not denied due process because of the State's failure to produce the counseling records, as there was no reasonable probability that, had the evidence been timely disclosed to the defense, the result of Petitioner's trial would have been different.View "Thompson v. Weber" on Justia Law

Plaintiff petitioned for a domestic abuse protection order against Defendant pursuant to S.D. Codified Laws chapter 25-10, arguing that Defendant's conduct constituted stalking under S.D. Codified Laws 22-19A-1 and that stalking under section 22-19A-1 constituted domestic abuse under section 25-10-1(1) if the stalking involved family or household members. The circuit court granted the protection order. The Supreme Court affirmed, holding that the circuit court properly interpreted section 25-10-1(1) and that a domestic abuse protection order based on stalking under chapter 25-10 did not require a criminal conviction for stalking under section 22-19A-1. View "Trumm v. Cleaver" on Justia Law

After a jury trial, Defendant was found guilty of three counts of distribution of a controlled drug or substance and three counts of possession of a controlled drug or substance. The Supreme Court affirmed the convictions, holding that the circuit court (1) did not violate Defendant’s due process rights in denying his motion to suppress an in-court identification stemming from an improper photo lineup; (2) did not err in refusing Defendant’s proposed jury instruction regarding cross-racial identification; and (3) did not err in denying Defendant’s motion for judgment of acquittal, as there was sufficient evidence to support the jury verdict. View "State v. Chuol" on Justia Law

This appeal concerned property located in Lincoln County that was unplatted and zoned for agricultural use. The property owner voluntarily petitioned for its annexation to the City of Sioux Falls. Sioux Falls subsequently adopted an annexation resolution under S.D. Codified Laws 9-4-1 annexing the property to be developed for a Walmart store. Neighbors of the property, joined as “Save Our Neighborhood,” petitioned the circuit court for writs of prohibition and certiorari, seeking to invalidate the City’s annexation resolution and to prohibit the City from rezoning the property. Petitioners argued that S.D. Codified Laws 9-4-5 required the City to obtain approval from the Lincoln County Board of County Commissioners before adopting a rule to annex the property. The circuit court denied the petitions. The Supreme Court affirmed the circuit court’s denial of Petitioners’ writs of certiorari and prohibition, holding that the Legislature did not intend section 9-4-5 to apply to a resolution adopted for a voluntary petition for annexation under section 9-4-1. View "Save our Neighborhood v. City of Sioux Falls" on Justia Law

Ten-month-old Kimimila Win Sunny Sarah Iron Cloud (Kimi) died while being cared for Jolyn Erickson. Kelly Laughlin was present when Kimi died from positional asphyxiation in her car seat. Prudence Millea, as special administrator for Kimi’s estate, brought a negligence action against Erickson and Laughlin for Kimi’s death. Default judgment was entered against Erickson, and the circuit court granted summary judgment for Lauglin, concluding that he had no legal duty to Kimi. Millea appealed, arguing (1) Laughlin interfered in Kimi’s care by instructing Erickson to place Kimi in her car seat and in the bedroom, and Laughlin had influence over Erickson such that she deferred to him in providing care for Kimi; and (2) therefore, Laughlin assumed a legal duty to provide reasonable care for Kimi. The Supreme Court affirmed, holding that Laughlin had no legal duty to care for Kimi. View "Millea v. Erickson" on Justia Law

Plaintiffs, who owned a landlocked parcel of land, brought suit against Defendant, claiming they had an implied easement over Defendant's land. The circuit court granted judgment for Plaintiffs, concluding that an easement implied from prior use existed. The Supreme Court reversed. On remand, Plaintiffs argued for a common law implied easement by necessity. The circuit court found three separate grounds that prevented Plaintiffs from being entitled to an implied easement by necessity: (1) the requirements for an implied easement by necessity were not met, (2) an adequate remedy at law barred equitable relief, and (3) South Dakota's Marketable Title Act (SDMTA) barred the action because the severance occurred outside SDMTA's twenty-two year provision. The Supreme Court affirmed on the ground that SDMTA barred Plaintiffs' action.View "Springer v. Cahoy" on Justia Law

Appellant suffered work-related injuries in 2000 and received workers' compensation benefits until 2004. Appellant filed another first report of injury in 2009 based on the same injuries. Employer denied benefits. Appellant filed a petition for rehearing. The Department of Labor & Regulation, Division of Labor & Management found that S.D. Codified Laws 62-7-35.1 barred Appellant's second claim for workers' compensation benefits because more than three years had passed between the date of the last payment of benefits and the date Appellant filed a written petition for a hearing. The circuit court affirmed. Appellant appealed, arguing section 62-7-35.1 should not apply to this case because his injuries were from cumulative trauma. The Supreme Court affirmed, holding that the cumulative trauma doctrine did not change section 62-7-35.1's application to this case because the cumulative trauma doctrine applies to the date of injury, which is irrelevant to section 62-7-35.1. View "Schuelke v. Belle Fourche Irrigation Dist." on Justia Law

After a jury trial, Appellant was convicted of driving under the influence of alcohol (DUI) and driving while having a 0.08 percent or more by weight of alcohol in the blood. Appellant appealed in part the trial court's admission of certain testimony regarding the Horizontal Gaze Nystagmus (HGN) test, which the arresting officer conducted during the stop of Appellant's vehicle. The Supreme Court affirmed the convictions, holding (1) even if the trial court erred in allowing the arresting officer to testify about the reliability of HGN testing and the correlation between an individual's performance on an HGN test and the individual's blood alcohol content, the error was harmless; and (2) the trial court did not err in denying Appellant's motion for a judgment of acquittal because there was sufficient evidence from which the jury could have convicted Appellant of DUI beyond a reasonable doubt.View "State v. Yuel" on Justia Law

Plaintiff, the former Jerauld County State's Attorney, brought a quo warranto action seeking to oust Defendant, the newly-elected State's Attorney, claiming Defendant did not qualify for and was not entitled to the office of Jerauld County State's Attorney. The circuit court denied relief, concluding that Defendant was the rightful holder of the office and was legally entitled to it. The Supreme Court affirmed, holding that because there was no evidence that Defendant usurped, intruded into, unlawfully held, or exercised the public office of Jerauld County State's Attorney, the circuit court correctly denied quo warranto relief. View "Bridgman v. Koch" on Justia Law

Plaintiff sued Defendant, a medical facility, for medical malpractice after a surgery on Plaintiff that was aborted. After a trial, the jury returned a verdict in favor of Defendant, finding that Plaintiff did not suffer damages legally caused by Defendant's negligence. Plaintiff filed a motion for a new trial, asserting, among other things, that the jury clearly erred in awarding no damages for the incisions that were made in the course of the aborted surgery. The circuit court granted the motion. The Supreme Court reversed, holding (1) because there was competent evidence supporting the jury's verdict in favor of Defendant on the issue of damages relating to Plaintiff's subsequent cardiac problems, the circuit court abused its discretion in granting a new trial on the question of causation and damages relating to Plaintiff's need for a pacemaker and her subsequent medical problems; and (2) the circuit court erred in granting a new trial on Plaintiff's claim for incisional pain because Plaintiff's claim for damages for incisional pain was barred by the statute of limitations. View "Lewis v. Sanford Med. Ctr." on Justia Law