Justia Labor & Employment Law Opinion Summaries

The Supreme Court reversed the judgment of the circuit court in favor of Appellee in this workers' compensation case, holding that an error led to the exclusion of relevant evidence and incorrect jury instructions that impacted the jury's verdict, which prejudiced Appellants.Fern Johnson sued her former employer and its workers' compensation carrier (collectively, Appellants) alleging bad faith and conversion based on their denial of previously ordered workers' compensation medical benefits. A jury returned a verdict for Johnson. The Supreme Court reversed and remanded the case for a new trial, holding (1) the circuit court did not err when it concluded that Appellants' legal obligation to pay Johnson's benefits was not fairly debatable; but (2) the circuit court erred when it determined that the lack of a reasonable basis to deny benefits necessarily impacted the jury's consideration of the separate bad faith element concerning Appellants' knowledge. View "Johnson v. United Parcel Service, Inc." on Justia Law

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

The Supreme Court affirmed the judgment of the circuit court denying Plaintiff's request for attorney fees under S.D. Codified Laws 60-11-24 after Plaintiff prevailed in an action seeking unpaid wages, holding that because this case was removed for a bench trial section 60-11-24 did not apply and Plaintiff was not entitled to recover attorney fees.After Defendant fired Plaintiff, Plaintiff brought an action in small claims court for unpaid wages. Defendant removed the action to circuit court, which ruled in favor of Plaintiff. Plaintiff requested attorney fees under section 60-11-24. The circuit court denied the request because the removal statute referenced in section 60-11-24 had been repealed. The Supreme Court affirmed, holding (1) the circuit court did not err in concluding that it could not award reasonable attorney fees under section 60-11-24 because of the repeal of S.D. Codified Laws 15-39-59; and (2) while attorney fees remain recoverable under section 60-11-24 for small claims cases removed to circuit court for a jury trial, this case was removed for a bench trial. View "Goin v. Houdashelt" on Justia Law

The Supreme Court reversed the judgment of the circuit court affirming the decision of the South Dakota Department of Labor dismissing Plaintiff's petition seeking workers' compensation benefits for lack of prosecution, holding that Plaintiff engaged in activity within a year before the motion to dismiss was filed.Plaintiff filed a petition with the Department seeking disability benefits and medical expenses arising from her workplace injury. Eventually, Employer/Insurer filed a motion to dismiss for lack of prosecution under ARSD 47:03:01:09, asserting that there had been no activity for at least one year and that Plaintiff had failed to show good cause for the delay. The Department granted the motion to dismiss. The Supreme Court reversed, holding that the Department abused its discretion in dismissing the appeal because its decision was based upon its erroneous conclusion that Plaintiff's participation in a vocational rehabilitation program was not "activity" under ARSD 47:03:01:09. View "Laplante v. GGNSC Madison, S.D." on Justia Law

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. View "Bonebright v. City Of Miller" on Justia Law

The Supreme Court affirmed the order of the circuit court affirming the decision of the Department of Labor determining that Appellant's knee surgery and related treatment were not compensable, holding that the Department did not err when it concluded that Appellant's work-related injury, in combination with his preexisting condition, did not remain a major contributing cause of his disability, impairment, or need for treatment.Appellant injured his left knee while working for Appellee. Appellee denied liability for Appellant's total knee replacement surgery and post-operative treatment. The Department found the work-related injury neither contributed independently nor was a major contributing cause of Appellant's need for surgery. The circuit court affirmed. The Supreme Court affirmed, holding that Appellant failed to prove causation under either S.D. Codified Laws 62-1-1(7)(b) or S.D. Codified Laws 62-1-1(7)(c). View "Armstrong v. Longview Farms, LLP" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of Mid-Century Insurance Company and dismissing Christina Blanchard's bad-faith complaint, holding that the circuit court properly granted summary judgment for Mid-Century.In her complaint, Blanchard alleged that Mid-Century pursued a "baseless and meritless appeal" from a decision of the South Dakota Department of Labor awarding Blanchard workers' compensation benefits. On appeal, Blanchard argued, among other things, that the circuit court erred in excluding evidence under the litigation conduct rule. The Supreme Court concluded that the circuit court's exclusion of the evidence under the litigation conduct rule was determinative of the appeal, and therefore it was unnecessary to discuss Blanchard's other claims of error, holding that the circuit court properly excluded the evidence and properly granted summary judgment based upon the other undisputed facts in the record. View "Blanchard v. Mid-Century Insurance Co." on Justia Law

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

The Supreme Court affirmed the order of the circuit court affirming the decision of the South Dakota Retirement System (SDRS) denying Debra Lee Anderson’s application for survivor spouse benefits under Deborah Cady’s retirement plan with the SDRS, holding that Anderson was not entitled to receive survivor benefits.Anderson and Cady both worked for the Rapid City Police Department. In 2012, Cady retired from the department. In 2015, Anderson and Cady married. In 2017, Cady died. Anderson applied for survivor spouse benefits, but the SDRS denied the application because Anderson and Cady were not married at the time of Cady’s retirement and because Anderson did not meet the definition of a “spouse” under S.D. Codified Laws 3-12-47(80). The South Dakota Officer of Hearing Examiners and circuit court both affirmed the SDRS. The Supreme Court affirmed, holding (1) under the relevant statutes, Anderson could not meet the definition of “spouse” and therefore was not entitled to Cady’s survivor benefits under South Dakota law; and (2) there was no discrimination on the basis of Anderson’s gender or sexual orientation. View "Anderson v. South Dakota Retirement System" on Justia Law

The Supreme Court reversed the decision of the circuit court affirming the decision of the South Dakota Department of Labor and Regulation awarding partial summary judgment in favor of Claimant for existing medical expenses she incurred after she suffered a workplace injury to her right foot that required surgery.This appeal concerned Claimant’s second motion for partial summary judgment to recover existing medical expenses after the Department first award partial summary judgment for Claimant’s incurred medical expenses. Employer and its insurer paid the outstanding medical expenses and then argued that a decision on the second motion was unnecessary because the issue was moot. The Department granted partial summary judgment in favor of Claimant. The circuit court affirmed. The Supreme Court reversed the circuit court’s judgment affirming the Department’s decision and remanded to the circuit court with instructions that the court order the Department to vacate its order and dismiss Claimant’s claim for medical expenses, holding that the claim for medical expenses set forth in Claimant’s motion for partial summary judgment became moot prior to the Department’s final order granting summary judgment and was moot when the circuit court reviewed it on appeal. View "Skjonsberg v. Menard, Inc." on Justia Law