South Dakota Case Commentaries

Lieutenant Governor May Cast Tie-Breaking Vote on Final Passage Under S.D. Const. art. IV, § 5

Date: Feb 20, 2026

Lieutenant Governor May Cast Tie-Breaking Vote on Final Passage Under S.D. Const. art. IV, § 5 Court: Supreme Court of South Dakota | Citation: 2026 S.D. 7 | Date: February 18, 2026 | Posture:...

FMCSRs Adopted in SDCL 49-28A-3 Set the Standard of Care for CMV Drivers and Can Support Negligence Per Se

Date: Feb 6, 2026

FMCSRs Adopted in SDCL 49-28A-3 Set the Standard of Care for CMV Drivers and Can Support Negligence Per Se Case: Hamer v. Duffy, Cornerstone Poured Foundations, Inc. Citation: 2026 S.D. 4 Court:...

Absolute Mandatory Auto Liability Coverage in Direct Actions Despite Policy Breach; Conditions Precedent Bar Only Excess Coverage

Date: Feb 6, 2026

Absolute Mandatory Auto Liability Coverage in Direct Actions Despite Policy Breach; Conditions Precedent Bar Only Excess Coverage Case: Kaiser Trucking, Inc. v. Liberty Mutual Fire Insurance Company,...

State v. Huante (2026 S.D. 6) — Rule 702/Daubert Bars Generic False-Confession Expert Testimony Lacking Reliable Methodology and Case “Fit”

Date: Feb 6, 2026

Rule 702/Daubert Requires Reliable Methodology and Case “Fit” for False-Confession Experts; Generic False-Confession Testimony Is Inadmissible Case: State v. Huante, 2026 S.D. 6 (S.D. Feb. 4, 2026) |...

Walton v. Huron Regional Medical Center — Daubert Requires Reliability Review of Differential Diagnosis, Not Just Component Tests

Date: Jan 31, 2026

Daubert Gatekeeping Must Evaluate a Physician’s Differential Diagnosis as a Whole (and Not Exclude Causation Opinions Solely Because a Supporting Quantitative Test Is Disputed) Introduction Walton v....

Estate of Webb (2026 S.D. 2): Enforcing Prenuptial Waivers of the Elective Share Under a Totality-of-the-Circumstances Voluntariness Inquiry and “Fair and Reasonable” Financial Disclosure

Date: Jan 16, 2026

Estate of Webb (2026 S.D. 2): Enforcing Prenuptial Waivers of the Elective Share Under a Totality-of-the-Circumstances Voluntariness Inquiry and “Fair and Reasonable” Financial Disclosure...

Estate of O'Neill (2026 S.D. 1): Collateral Estoppel Cannot Conclusively Establish Prior Credibility Findings in a Different Case

Date: Jan 9, 2026

Collateral Estoppel Requires Identical, Essential Issues—Prior Credibility Findings Cannot Be Treated as Conclusive in a Separate Undue-Influence Will Contest Case: In the Matter of the Estate of...

Referral Agreements Tied to Servicing Are Not At-Will, But “Renewal” Requires a Continued Client Relationship—Affiliate “In-House” Servicing Ends Residual Fees as a Matter of Law

Date: Jan 2, 2026

Referral Agreements Tied to Servicing Are Not At-Will, But “Renewal” Requires a Continued Client Relationship—Affiliate “In-House” Servicing Ends Residual Fees as a Matter of Law Case: Ljp...

South Dakota Refines Economic Duress and Clarifies Fiduciary Duties in Manager‑Managed LLCs: Commentary on Trigger Energy Holdings v. Stevens

Date: Dec 26, 2025

South Dakota Refines Economic Duress and Clarifies Fiduciary Duties in Manager‑Managed LLCs: Commentary on Trigger Energy Holdings, LLC v. Stevens, 2025 S.D. 72 I. Introduction In Trigger Energy...

State v. Biteler and the Meaning of “Report” Under SDCL 22‑11‑9(3) in a Digital Monitoring Era

Date: Dec 26, 2025

State v. Biteler and the Meaning of “Report” Under SDCL 22‑11‑9(3) in a Digital Monitoring Era I. Introduction In State v. Biteler, 2025 S.D. 73, the Supreme Court of South Dakota addressed a modern...

Specific Evidence, Not Generalized Religious Fears: Jessop v. Combs and Unsupervised Parenting Time in the Shadow of Alleged FLDS Ties

Date: Dec 20, 2025

Specific Evidence, Not Generalized Religious Fears: Jessop v. Combs and Unsupervised Parenting Time in the Shadow of Alleged FLDS Ties I. Introduction The South Dakota Supreme Court’s decision in...

Open‑Ended Answer Extensions as “Good Cause” Against Failure‑to‑Prosecute Dismissals: Commentary on Arrowsmith v. Odle, 2025 S.D. 70

Date: Dec 20, 2025

Open‑Ended Answer Extensions as “Good Cause” Precluding Failure‑to‑Prosecute Dismissals: A Commentary on Arrowsmith v. Odle, 2025 S.D. 70 I. Introduction In Arrowsmith v. Odle, 2025 S.D. 70, the...

State v. Long: Cross‑Jurisdictional Other‑Act Evidence and Psychological Coercion in Familial Rape and Abuse Prosecutions

Date: Dec 13, 2025

State v. Long: Cross‑Jurisdictional Other‑Act Evidence and Psychological Coercion in Familial Rape and Abuse Prosecutions I. Introduction In State v. Long, 2025 S.D. 69, the Supreme Court of South...

State v. Clemensen: Expansive Construction of Elder Theft by Exploitation for POA Misuse and Encumbrance of Trust Property

Date: Nov 29, 2025

State v. Clemensen: Expansive Construction of Elder Theft by Exploitation for POA Misuse and Encumbrance of Trust Property Introduction In State v. Clemensen, 2025 S.D. 68, the Supreme Court of South...

King v. King: Pending Business Lawsuits as Marital Property in South Dakota Divorce Law

Date: Nov 20, 2025

King v. King: Pending Business Lawsuits as Marital Property in South Dakota Divorce Law I. Introduction In King v. King, 2025 S.D. 67, the Supreme Court of South Dakota addressed a question at the...

No Federal-Style Lodestar Presumption in Condemnation Fee Awards: Commentary on City of Sioux Falls v. Johnson Properties, 2025 S.D. 66

Date: Nov 20, 2025

No Federal-Style Lodestar Presumption in Condemnation Fee Awards: City of Sioux Falls v. Johnson Properties, 2025 S.D. 66 I. Introduction In City of Sioux Falls v. Johnson Properties, LLC, 2025 S.D....

Fraud Between Spouses Under Rule 60(b)(3): Trumble v. Trumble and the Duty of Full Asset Disclosure in Divorce Settlements

Date: Nov 13, 2025

Fraud Between Spouses Under Rule 60(b)(3): Trumble v. Trumble and the Duty of Full Asset Disclosure in Divorce Settlements I. Introduction The South Dakota Supreme Court’s decision in Trumble v....

Baseless Allegations of Judicial Fabrication as Professional Misconduct: Commentary on In re Discipline of Volesky, 2025 S.D. 62

Date: Nov 13, 2025

Baseless Allegations of Judicial Fabrication as Professional Misconduct: Commentary on In re Discipline of Volesky, 2025 S.D. 62 I. Introduction The South Dakota Supreme Court’s decision in In the...

Expert Testimony and Technical Construction Disputes in Contract and Tort: Commentary on RTI, LLC v. Pro Engineering, Inc., 2025 S.D. 64

Date: Nov 13, 2025

Expert Testimony and Technical Construction Disputes in Contract and Tort: Commentary on RTI, LLC v. Pro Engineering, Inc., 2025 S.D. 64 I. Introduction RTI, LLC v. Pro Engineering, Inc., 2025 S.D....

Coyle v. McFarland: Excusable Neglect, Rule 56(f) Continuances, and Public Right‑of‑Way Disputes in South Dakota Trespass Law

Date: Nov 13, 2025

Coyle v. McFarland: Excusable Neglect, Rule 56(f) Continuances, and Public Right‑of‑Way Disputes in South Dakota Trespass Law I. Introduction In Coyle v. McFarland, 2025 S.D. 63, the South Dakota...