Humble v. Wyant, 843 N.W.2d 334

Humble sued Wyant for specific performance of Humble's option to purchase Humble Ranch; Wyant counterclaimed for rent.
Ranch is 4,820 acres in Perkins County, owned by Wyant since 2005; Humble is a family member who sought to exercise the option.
In 2005, Wyant bought out Bruce and Bessie Humble interests and granted Humble a two-year option to purchase; Casey (Humble's son) occupied the ranch.
Option required a Purchase Agreement within 30 days after exercise, seller's right to match financing, and closing within six months but before option expiry.
Humble exercised the option in June 2006; no purchase agreement or matching financing occurred before the January 10, 2008 expiry; discussions and partial financing terms occurred in 2006–2007; the option expired without a signed purchase agreement.
Court denied specific performance and awarded rent to Wyant on counterclaim; Humble appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether specific performance was proper given missed conditions.	Humble	Wyant	No; court reasonably denied due to material noncompliance by Humble.
Whether Humble partially performed and the partial-performance exception applies.	Humble	Wyant	Remand for findings on partial performance and full compensation feasibility.
Whether there was a valid express or implied rent obligation.	Humble	Wyant	Rent claim rejected; no express contract; no viable implied contract with Humble; if any, with Casey.

Advanced Recycling Sys., L.L.C. v. Se. Props. Ltd. P’ship, 2010 S.D. 70 (S.D. 2010) (early-stage option contract becomes bilateral upon acceptance)
Kuhfeld v. Kuhfeld, 292 N.W.2d 312 (S.D. 1980) (specific performance requires mutuality and full compliance with conditions)
Renner v. Crisman, 80 S.D.532 (S.D. 1964) (early authority on conditions precedent and specific performance)
Lamar Adver. of S.D., Inc. v. Heavy Constructors, Inc., 745 N.W.2d 371 (S.D. 2008) (equitable balancing governs specific performance; abuse-of-discretion review)