Justia Contracts Opinion Summaries

Articles Posted in South Dakota Supreme Court
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The Supreme Court affirmed the order of the circuit court granting Defendants' motion for judgment on the pleadings and dismissing Plaintiff's fraud and deceit claims, holding that the claims were time barred.Plaintiff sued a law firm and its attorneys, alleging legal malpractice, fraud and deceit related to their representation of Plaintiff on criminal charges. The circuit court granted judgment on the pleadings for Defendants, concluding that the claims were time-barred by the three-year statute of repose for legal malpractice under S.D. Codified Laws 15-2-14.2. Plaintiff appealed, arguing that the circuit court erred in dismissing the fraud and deceit claims because those claims were subject to a six-year statute of limitations. The Supreme Court affirmed, holding (1) Plaintiff's fraud and deceit claims were subsumed within his malpractice claim; and (2) therefore, all of Plaintiff's claims were precluded under the repose statute. View "Slota v. Imhoff" on Justia Law

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The Supreme Court reversed the order of the circuit court granting summary judgment to Defendant in this breach of contract case, holding that the evidence was sufficient to refute Defendant's argument that the alleged agreement was unenforceable.In granting summary judgment, the circuit court concluded that the alleged agreement relating to the transfer of real property was unenforceable because it was for an unlawful purpose, violated the statute of frauds, and lacked consideration. The Supreme Court reversed, holding (1) the parties' writings sufficiently set forth the substance of the parties' agreement to satisfy the statute of frauds; (2) the circuit court erred when it summarily concluded that the only reason Plaintiff transferred the property was to defraud the IRS; and (3) the evidence was sufficient to refute Defendant's argument that the alleged agreement failed as a matter of law for lack of consideration. View "Hanna v. Landsman" on Justia Law

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The Supreme Court affirmed the order of the circuit court granting summary judgment for Hospital on Nurse's claims for wrongful discharge, breach of contract, and defamation, holding that summary judgment was proper.Hospital terminated Nurse after it discovered errors in Nurse's documentation of controlled substances and Nurse's inability to account for controlled substances revamped from the dispensing system. Nurse brought suit against Hospital alleging several claims. The circuit court granted summary judgment for Hospital on all claims. The Supreme Court affirmed, holding that summary judgment was properly granted in favor of Hospital. View "Henning v. Avera McKennan Hospital" on Justia Law

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The Supreme Court dismissed for lack of appellate jurisdiction Appellants' appeal from the circuit court's order granting summary judgment dismissing some but not resolving all of the parties' claims, holding that the circuit court's summary judgment order was indisputably not final.The circuit court's order granting summary judgment did not resolve all of the parties' claims, and it was not certified as a final decision prior to Appellants' appeal. The Supreme Court dismissed the appeal without reaching the merits of the appeal, holding that because the circuit court resolved only part of the case and the summary judgment order did not cite S.D. Codified Laws 15-6-54(b) (Rule 54(b)), did not designate the order as final, and was not accompanied by a reasoned statement supporting a Rule 54(b) certification, this Court lacked appellate jurisdiction. View "Huls v. Meyer" on Justia Law

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In this dispute over the sale proceeds from an auction of cattle the Supreme Court affirmed in part and reversed in part the entry of partial summary judgment on Plaintiff's claim for the sale proceeds, holding that Defendant had a right to pursue his disputed claim for an additional $12,500.Pursuant to the terms of a sales agreement Plaintiff purchased cows and calves from Defendant. The agreement required Plaintiff to pay for the cattle in installments, with Defendant retaining a security interest in the cattle. After Plaintiff sold the remaining cows purchased from Defendant at auction Plaintiff calculated a payoff to Defendant to satisfy the balance of the agreement, with a remaining balance paid to Plaintiff. When Defendant refused to allow any of the sale proceeds to be released from the auction barn Plaintiff brought this action. The circuit court granted Plaintiff's motion for partial summary judgment on its claim for the sale proceeds and entered judgment against Defendant for $185,718. The Supreme Court held (1) Defendant's appeal from the order denying his motion for change of venue is dismissed for lack of jurisdiction; and (2) disputed facts existed concerning Defendant's claim that he was owed an additional $12,500 under the sales agreement. View "Stromberger Farms, Inc. v. Johnson" on Justia Law

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The Supreme Court reversed the circuit court's dismissal of Plaintiff's deceit claim and affirmed the circuit court's rulings as to Plaintiff's breach of contract, negligent misrepresentation and fraud claims and as to Defendants' counterclaim seeking damages under two three-year lease agreements allowing Plaintiff to rent Defendants' ranch, holding that the circuit court erred in concluding that Defendants fraudulently induced Plaintiff to enter into one of the leases.Following disputes between the parties, Defendants refused Plaintiff's lease payments for the second year. Plaintiff filed suit, and Defendants counterclaimed. The trial court found one lease valid and binding and the other lease valid but voidable. A jury awarded damages to both parties. The Supreme Court reversed in part and otherwise affirmed, holding (1) the circuit court did not abuse its discretion in its evidentiary rulings and in its jury instructions; (2) the circuit court did not err when it found the second lease voidable instead of void; and (3) the circuit court erred when it granted Defendants' motion for summary judgment on Plaintiff's claim that Defendants fraudulently induced him to enter into the second lease. The Court remanded the case for a new trial on Plaintiff's deceit claim. View "Knecht v. Evridge" on Justia Law

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The Supreme Court reversed in part the circuit court's judgment granting Defendants summary judgment in part and, after a trial, entering a judgment consistent with the jury verdict, holding that a new trial on Plaintiffs' conversion and unjust enrichment claims was necessary.Plaintiffs loaned Defendants nearly $1.2 million, securing the loans with fifty-five promissory notes. Plaintiffs later sued Defendants for breach of contract, unjust enrichment, and conversion. Defendants counterclaimed for conversion and unjust enrichment. The circuit court granted Defendants summary judgment in part, dismissing forty-eight of the promissory notes as time barred and concluding that the related mortgage was unenforceable. After a trial, the jury returned a verdict for Plaintiffs on their breach of contract claim, rejected their claim for conversion, and awarded Defendants $135,000 on their conversion counterclaim. The jury then rendered an advisory verdict for Defendants as to the parties' competing claims for unjust enrichment. The Supreme Court reversed in part, holding that the circuit court (1) abused its discretion by giving a missing witness instruction at trial, (2) erred by allowing the jury to determine the date to begin calculating interest on the enforceable promissory notes, and (3) erred in allowing the jury to consider evidence of the time-barred notes when considering Plaintiffs' claims of unjust enrichment. View "Mealy v. Prins" on Justia Law

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The Supreme Court affirmed the judgment of the trial court granting summary judgment in favor of Defendants and dismissing Plaintiff's suit claiming that he was financially damaged by Defendants' fraud and conspiracy and deprived of control over the family ranch, holding that the circuit court properly concluded that Plaintiff's suit was time barred.This case arose out of a family dispute over ownership and control of a family ranch. Plaintiff sued his mother, brothers, former attorney, and two business entities charging Defendants with, among other things, conversion, fraud, and conspiracy to commit fraud and requesting punitive and compensatory damages. The circuit court granted Defendants' motions for summary judgment on all claims, concluding that Plaintiff's claims were time barred. The circuit court then granted Defendants' motions for attorney fees, concluding that Plaintiff's lawsuit was frivolous and malicious. The Supreme Court affirmed, holding that the circuit court (1) properly concluded that Plaintiff's suit was time barred; and (2) did not abuse its discretion by awarding attorney fees to Defendants. View "Healy v. Osborne" on Justia Law

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The Supreme Court affirmed the order of the circuit court dismissing this suit against Marty Indian School (MIS), a legal entity of the Yankton Sioux Tribe, for a lack of subject matter jurisdiction based on federal preemption, holding that the circuit court lacked subject matter jurisdiction to hear Plaintiff's claims against MIS.Plaintiff, the former high school principal at MIS, sued MIS and other involved parties after he was terminated. Plaintiff alleged claims for breach of contract, breach of settlement agreement, wrongful termination, libel, and slander, and requested punitive damages. The circuit court dismissed the complaint on the grounds of tribal sovereign immunity, immunity of tribal officials and employees, infringement of tribal sovereignty, and federal preemption. The Supreme Court affirmed the dismissal solely on a lack of subject matter jurisdiction based on federal preemption, holding that state court action in this dispute was preempted by federal law. View "Stathis v. Marty Indian School" on Justia Law

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The Supreme Court affirmed the decision of the dismissing The Institute of Range and the American Mustang’s (IRAM) lawsuit seeking to void a seventeen-year-old deed of conservation easement and to quiet title to its property, holding that the circuit court did not err in granting summary judgment in favor of The Nature Conservancy on IRAM’s claims.Specifically, the Court held (1) because the statute of limitations expired more than six years prior to IRAM’s suit, the circuit court did not err in granting The Nature Conservancy summary judgment on IRAM’s fraud claim; (2) summary judgment was properly granted on IRAM’s ultra vires claim and claim to vacate deed for no meeting of the minds; and (3) the circuit court did not err in granting The Nature Conservancy summary judgment on IRAM’s claim to vacate the deed for failure of consideration. View "Institute of Range & American Mustang v. Nature Conservancy" on Justia Law