Black Bear v. Mid-Central Educational Cooperative

Citation: 2020 S.D. 14

Opinion Date: March 18, 2020

Judge: David Gilbertson

Areas of Law: Civil Procedure, Education Law

The Supreme Court affirmed the decision of the circuit court dismissing students' claims seeking to recover for lost funding for services denied to them under the GEAR UP program due to mismanagement and embezzlement, holding that the students lacked standing to bring their claims. The students in this case attended schools that GEAR UP was meant to serve and now attended college. The students claimed to have been denied GEAR UP benefits in their schools due to embezzlement and negligent supervision, among other claims. The circuit court granted summary judgment in favor of the defendants, concluding that the students had standing to bring their claims but that the claims were preempted by federal law. The Supreme Court affirmed but on other grounds, holding the students failed to show standing because they failed to show how an award of monetary damages would redress the alleged past loss of supplemental educational services.

State v. Wolf

Citation: 2020 S.D. 15

Opinion Date: March 18, 2020

Judge: Jensen

Areas of Law: Criminal Law

The Supreme Court reversed the judgment of the circuit court granting Defendant's motion for judgment of acquittal on his aggravated assault conviction, holding that there was sufficient evidence on the record, and inferences that could have been drawn therefrom, to sustain a reasonable theory of guilt of aggravated assault by extreme indifference beyond a reasonable doubt. A jury convicted Defendant of aggravated assault and simple assault. The circuit court denied Defendant's motion for judgment of acquittal on both charges at the close of the State's evidence. The court, however, granted Defendant's renewed motion for judgment of acquittal on the aggravated assault conviction after the trial. The Supreme Court reversed and remanded to the circuit court with instructions to reinstate the jury's verdict, holding that the circuit court erred in granting Defendant's motion for judgment of acquittal because there was sufficient evidence to support the jury's guilty verdict.

Bonebright v. City Of Miller

Citation: 2020 S.D. 16

Opinion Date: March 18, 2020

Judge: Salter

Areas of Law: Government & Administrative Law, Labor & Employment Law, Personal Injury

The Supreme Court affirmed the judgment of the circuit court affirming the decision of the Department of Labor to award benefits to James Bonebright's widow, Stephanie, after Bonebright died from injuries he sustained in a work-related accident, holding that the workers' compensation claim was not precluded by willful misconduct. Bonebright's employer, the City of Miller, and the City's workers' compensation provider denied workers' compensation liability on the ground that Bonebright had engaged in willful misconduct. Stephanie petitioned the Department for medical and funeral expenses along with indemnity benefits as a surviving spouse. The Department awarded Stephanie benefits, concluding that although Bonebright had engaged in willful misconduct, the City had not established that Bonebright's failure to follow safety precautions was a proximate cause of his injury and death. The circuit court reversed the Department's willful misconduct finding. The Supreme Court affirmed, holding that Stephanie's claim was not precluded by willful misconduct because the City did not demonstrate bona fide enforcement of its safety rules.