prima facie challenge (South Dakota) · Go Syfert
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prima facie challenge in South Dakota

13 South Dakota opinions name it 1 courts 1928–2023 1 in the last five years

The cases below were cited by South Dakota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
State v. Lohnesgreen
sd · 1988 · cited in 4 South Dakota opinions naming this issue, 1993–2008
2 sentences

1996State v. Arguello, 502 N.W.2d 548, 553 (S.D.1993); State v. Lohnes, 432 N.W.2d 77, 83 (S.D.1988) (citing Duren v. Missouri 439 U.S. 357 , 99 S.Ct. 664 , 58 L.Ed.2d 579 (1979); Taylor v. Louisiana, 419 U.S. 522 , 95 S.Ct. 692 , 42 L.Ed.2d 690 (1975)). [¶ 22J To establish a prima facie challenge, a defendant must show that: (1) the group excluded is a “distinct” group in the community; (2) the representation of this group in jury pools is not fair and reasonable in relation to the number of such persons in the community; and (3) this underrepresen-tation is due to the systematic exclusion of the

1996State v. Arguello, 502 N.W.2d 548, 553 (S.D.1993); State v. Lohnes, 432 N.W.2d 77, 83 (S.D.1988) (citing Duren v. Missouri, 439 U.S. 357 , 99 S.Ct. 664 , 58 L.Ed.2d 579 (1979); Taylor v. Louisiana, 419 U.S. 522 , 95 S.Ct. 692 , 42 L.Ed.2d 690 (1975)). [¶ 22] To establish a prima facie challenge, a defendant must show that: (1) the group excluded is a "distinct" group in the community; (2) the representation of this group in jury pools is not fair and reasonable in relation to the number of such persons in the community; and (3) this underrepresentation is due to the systematic exclusion of the

34
West v. John Morrell & Co.green
sd · 1990 · cited in 1 South Dakota opinions naming this issue, 2023–2023
1 sentence

2023As used in this section, the term, criminal prosecution, includes arresting, detaining in custody, and charging or prosecuting the defendant. [¶25.] In South Dakota, “[n]o part of the code of laws . . . shall be construed as retroactive unless such intention plainly appears.” SDCL 2-14-21. “‘[A] statute will not operate retroactively unless the act clearly expresses an intent to do so’ or the change is merely procedural and not substantive.” State v. Krause, 2017 S.D. 16 , ¶ 16 n.7, 894 N.W.2d 382 , 387 n.7 (alteration in original) (quoting West v. John -11- #29902 Morrell & Co., 460 N.W.2d 74

11
McDonnell Douglas Corp. v. Greengreen
scotus · 1973 · cited in 1 South Dakota opinions naming this issue, 2015–2015
2 sentences

2015See McDonnell Douglas, 411 U.S. at 802 , 93 S.Ct. at 1824 ; Lord v. Hy-Vee Food Stores, 2006 S.D. 70 , ¶ 18, 720 N.W.2d 443, 449-50 .

2015See McDonnell Douglas, 411 U.S. at 802 , 93 S.Ct. at 1824 ; Lord v. Hy-Vee Food Stores, 2006 S.D. 70 , ¶ 18, 720 N.W.2d 443, 449-50 .

11
Primeaux v. Dooleygreen
sd · 2008 · cited in 1 South Dakota opinions naming this issue, 2009–2009
2 sentences

2009Primeaux v. Dooley, 2008 SD 22, ¶ 12 , 747 N.W.2d 137, 141 (citations omitted). [¶ 49.] Regarding the first prong, the State concedes and the circuit court found that African Americans are a distinct group.

2009Primeaux v. Dooley, 2008 SD 22, ¶ 12 , 747 N.W.2d 137, 141 (citations omitted). [¶ 49.] Regarding the first prong, the State concedes and the circuit court found that African Americans are a distinct group.

11
William J. Federer v. Richard A. Gephardt, Individually Joyce A. Aboussie, Individually James A. Larrew, Individually and John Doesgreen
ca8 · 2004 · cited in 1 South Dakota opinions naming this issue, 2005–2005
2 sentences

2005See also Federer v. Gephardt, 363 F.3d 754, 758 (8th Cir.2004) (holding that a claim under the equal protection section of section 1985(3) requires proof of class-based animus). [¶ 32.] On appeal, the parents do not assert, nor is there any evidence in the record to suggest, that racial or other class-based animus existed on the part of *503 the City. [8] Therefore, a prima facie claim of civil rights violations under § 1985(3) has not been established. [¶ 33.] Based on the above, there is no genuine issue of material fact that the parents established civil rights violations under 42 USC § 198

2005See also Federer v. Gephardt, 363 F.3d 754, 758 (8th Cir.2004) (holding that a claim under the equal protection section of section 1985(3) requires proof of class-based animus). [¶ 32.] On appeal, the parents do not assert, nor is there any evidence in the record to suggest, that racial or other class-based animus existed on the part of the City. 8 Therefore, a prima facie claim of civil rights violations under § 1985(3) has not been established. [¶ 33.] Based on the above, there is no genuine issue of material fact that the parents established civil rights violations under 42 USC § 1983 or §

11
State v. Arguellogreen
sd · 1993 · cited in 1 South Dakota opinions naming this issue, 1996–1996
2 sentences

1996State v. Arguello, 502 N.W.2d 548, 553 (S.D.1993); State v. Lohnes, 432 N.W.2d 77, 83 (S.D.1988) (citing Duren v. Missouri 439 U.S. 357 , 99 S.Ct. 664 , 58 L.Ed.2d 579 (1979); Taylor v. Louisiana, 419 U.S. 522 , 95 S.Ct. 692 , 42 L.Ed.2d 690 (1975)). [¶ 22J To establish a prima facie challenge, a defendant must show that: (1) the group excluded is a “distinct” group in the community; (2) the representation of this group in jury pools is not fair and reasonable in relation to the number of such persons in the community; and (3) this underrepresen-tation is due to the systematic exclusion of the

1996State v. Arguello, 502 N.W.2d 548, 553 (S.D.1993); State v. Lohnes, 432 N.W.2d 77, 83 (S.D.1988) (citing Duren v. Missouri, 439 U.S. 357 , 99 S.Ct. 664 , 58 L.Ed.2d 579 (1979); Taylor v. Louisiana, 419 U.S. 522 , 95 S.Ct. 692 , 42 L.Ed.2d 690 (1975)). [¶ 22] To establish a prima facie challenge, a defendant must show that: (1) the group excluded is a "distinct" group in the community; (2) the representation of this group in jury pools is not fair and reasonable in relation to the number of such persons in the community; and (3) this underrepresentation is due to the systematic exclusion of the

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in South Dakota. Read the followed side critically anyway.

Also cited on this issue (12)

CaseCitedYears
Turner v. Fouche green
scotus · 1970
2 sentences

2008Id. ¶ 10 (quoting State v. Lohnes, 432 N.W.2d 77, 83-84 (S.D.1988) (citing Duren v. Missouri, 439 U.S. 357, 363 , 99 S.Ct. 664, 668 , 58 L.Ed.2d 579 (1979); Turner v. Fouche, 396 U.S. 346 , 90 S.Ct. 532 , 24 L.Ed.2d 567 (1970))). [¶ 13.] In this case, the first element is satisfied, as the State does not dispute that Native Americans are a distinct group.

2008Id. ¶ 10 (quoting State v. Lohnes, 432 N.W.2d 77, 83-84 (S.D.1988) (citing Duren v. Missouri, 439 U.S. 357, 363 , 99 S.Ct. 664, 668 , 58 L.Ed.2d 579 (1979); Turner v. Fouche, 396 U.S. 346 , 90 S.Ct. 532 , 24 L.Ed.2d 567 (1970))). [¶ 13.] In this case, the first element is satisfied, as the State does not dispute that Native Americans are a distinct group.

41988–2008
Duren v. Missouri green
scotus · 1979
2 sentences

1996State v. Arguello, 502 N.W.2d 548, 553 (S.D.1993); State v. Lohnes, 432 N.W.2d 77, 83 (S.D.1988) (citing Duren v. Missouri 439 U.S. 357 , 99 S.Ct. 664 , 58 L.Ed.2d 579 (1979); Taylor v. Louisiana, 419 U.S. 522 , 95 S.Ct. 692 , 42 L.Ed.2d 690 (1975)). [¶ 22J To establish a prima facie challenge, a defendant must show that: (1) the group excluded is a “distinct” group in the community; (2) the representation of this group in jury pools is not fair and reasonable in relation to the number of such persons in the community; and (3) this underrepresen-tation is due to the systematic exclusion of the

1996State v. Arguello, 502 N.W.2d 548, 553 (S.D.1993); State v. Lohnes, 432 N.W.2d 77, 83 (S.D.1988) (citing Duren v. Missouri 439 U.S. 357 , 99 S.Ct. 664 , 58 L.Ed.2d 579 (1979); Taylor v. Louisiana, 419 U.S. 522 , 95 S.Ct. 692 , 42 L.Ed.2d 690 (1975)). [¶ 22J To establish a prima facie challenge, a defendant must show that: (1) the group excluded is a “distinct” group in the community; (2) the representation of this group in jury pools is not fair and reasonable in relation to the number of such persons in the community; and (3) this underrepresen-tation is due to the systematic exclusion of the

41988–2008
State v. Krause neutral
sd · 2017
1 sentence

2023As used in this section, the term, criminal prosecution, includes arresting, detaining in custody, and charging or prosecuting the defendant. [¶25.] In South Dakota, “[n]o part of the code of laws . . . shall be construed as retroactive unless such intention plainly appears.” SDCL 2-14-21. “‘[A] statute will not operate retroactively unless the act clearly expresses an intent to do so’ or the change is merely procedural and not substantive.” State v. Krause, 2017 S.D. 16 , ¶ 16 n.7, 894 N.W.2d 382 , 387 n.7 (alteration in original) (quoting West v. John -11- #29902 Morrell & Co., 460 N.W.2d 74

12023–2023
Lord v. Hy-Vee Food Stores green
sd · 2006
1 sentence

2015See McDonnell Douglas, 411 U.S. at 802 , 93 S.Ct. at 1824 ; Lord v. Hy-Vee Food Stores, 2006 S.D. 70 , ¶ 18, 720 N.W.2d 443, 449-50 .

12015–2015
Taylor v. Louisiana green
scotus · 1975
2 sentences

1996State v. Arguello, 502 N.W.2d 548, 553 (S.D.1993); State v. Lohnes, 432 N.W.2d 77, 83 (S.D.1988) (citing Duren v. Missouri 439 U.S. 357 , 99 S.Ct. 664 , 58 L.Ed.2d 579 (1979); Taylor v. Louisiana, 419 U.S. 522 , 95 S.Ct. 692 , 42 L.Ed.2d 690 (1975)). [¶ 22J To establish a prima facie challenge, a defendant must show that: (1) the group excluded is a “distinct” group in the community; (2) the representation of this group in jury pools is not fair and reasonable in relation to the number of such persons in the community; and (3) this underrepresen-tation is due to the systematic exclusion of the

1996State v. Arguello, 502 N.W.2d 548, 553 (S.D.1993); State v. Lohnes, 432 N.W.2d 77, 83 (S.D.1988) (citing Duren v. Missouri 439 U.S. 357 , 99 S.Ct. 664 , 58 L.Ed.2d 579 (1979); Taylor v. Louisiana, 419 U.S. 522 , 95 S.Ct. 692 , 42 L.Ed.2d 690 (1975)). [¶ 22J To establish a prima facie challenge, a defendant must show that: (1) the group excluded is a “distinct” group in the community; (2) the representation of this group in jury pools is not fair and reasonable in relation to the number of such persons in the community; and (3) this underrepresen-tation is due to the systematic exclusion of the

11996–1996
Pribbenow v. Van Sambeek green
sd · 1988
1 sentence

1993As it did in Pribbenow , SDCL 30-27-23 provided during the duration of these proceedings that, “[o]f two persons equally entitled to the custody in other respects, preference is to be given as follows: (1) to a parent[.]” 2 The custody preferences of SDCL 25-5-10, Pribbenow, supra, and SDCL 30-27-23 would appear to provide Alicia a prima facie defense to Charles’ adverse claim to custody of the youngest child if Alicia is able to muster sufficient proof that the child is an illegitimate child and not Charles’ natural child. 3 Therefore, we conclude that mother has established a probable merito

11993–1993
Ackerman v. Burgard green
sd · 1961
1 sentence

1987Id.

11987–1987
Independent School Dist. v. Scott neutral
sd · 1927
1 sentence

1934Under the rule announced in the cases of Independent School District v. Scott, 51 S. D. 187, 212 N. W. 863 ; Onida Independent School District v. Groth, 53 S. D. 458, 221 N. W. 49 ; Independent School District of City of Brookings v. Flittie, 54 S. D. 526, 223 N. W. 728 , it is only necessary to show in avoidance of such defense that the defendant was an officer of the depositary bank, was charged with knowing of the unsoundness of the depositary, and did not communicate such information promptly to the authority designating the depositary.

11934–1934
Onida Independent School Dist. No. 1 v. Groth green
sd · 1928
1 sentence

1934Under the rule announced in the cases of Independent School District v. Scott, 51 S. D. 187, 212 N. W. 863 ; Onida Independent School District v. Groth, 53 S. D. 458, 221 N. W. 49 ; Independent School District of City of Brookings v. Flittie, 54 S. D. 526, 223 N. W. 728 , it is only necessary to show in avoidance of such defense that the defendant was an officer of the depositary bank, was charged with knowing of the unsoundness of the depositary, and did not communicate such information promptly to the authority designating the depositary.

11934–1934
Independent School Dist. v. Flittie neutral
sd · 1929
1 sentence

1934Under the rule announced in the cases of Independent School District v. Scott, 51 S. D. 187, 212 N. W. 863 ; Onida Independent School District v. Groth, 53 S. D. 458, 221 N. W. 49 ; Independent School District of City of Brookings v. Flittie, 54 S. D. 526, 223 N. W. 728 , it is only necessary to show in avoidance of such defense that the defendant was an officer of the depositary bank, was charged with knowing of the unsoundness of the depositary, and did not communicate such information promptly to the authority designating the depositary.

11934–1934
Board of Education of the Independent School District v. Whisman green
sd · 1930
1 sentence

1934The last-cited case was followed by the case of Board of Education v. Whisman, 56 S. D. 472, 229 N. W. 522 , wherein the rule above announced was further extended by the holding of this court that the prima facie defense having been established by proving the designation of the depositary and its closing, the plaintiff is entitled to meet this defense by showing other facts in avoidance.

11934–1934
Griswold Linseed Oil Co. v. Lee green
sd · 1891
1 sentence

1928Griswold Linseed Oil Co. v. Lee, 1 S. D. 531, 47 N. W. 955 , 36 Am.

11928–1928

Statutes the citing opinions construe

SD § S.D. Codified Laws § 16-13-10.1 (4) SD § S.D. Codified Laws § 16-13-4.1 (3) SD § S.D. Codified Laws § 22-16-15 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 1066 (1887–2026) NJ 749 (1903–2026) TX 336 (1881–2026) NY 308 (1827–2026) PA 296 (1885–2026) AL 270 (1888–2026) MI 249 (1899–2026) WA 193 (1893–2026) IL 180 (1892–2026) OH 166 (1889–2026) NC 163 (1887–2026) IN 147 (1860–2026) MD 123 (1870–2026) TN 123 (1940–2025) WI 101 (1908–2025) IA 100 (1865–2026) LA 99 (1907–2025) VA 99 (1852–2026) FL 93 (1939–2025) GA 87 (1903–2021) MS 76 (1879–2023) MO 65 (1884–2023) NM 51 (1988–2025) KY 51 (1878–2025) WV 46 (1883–2025) MA 44 (1860–2025) ME 44 (1878–2023) CT 43 (1913–2021) OK 40 (1908–2014) AR 40 (1897–2024) CO 37 (1896–2025) AZ 36 (1935–2026) MN 35 (1901–2025) NV 33 (1936–2024) SC 31 (1907–2026) DC 31 (1976–2025) OR 29 (1901–2025) MT 28 (1901–2022) UT 26 (1897–2026) KS 26 (1918–2026) NH 22 (1860–2025) NE 22 (1882–2026) ID 18 (1912–2024) ND 18 (1907–2012) DE 18 (1947–2026) AK 16 (1971–2025) VT 16 (1849–2026) RI 15 (1977–2021) SD 13 (1928–2023) HI 13 (1972–2023) WY 9 (1961–2026) VI 4 (2009–2024) GU 3 (2021–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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