Oyen v. Lawrence Cty. Comm'n
2017 SD 81
| S.D. | 2017Background
- South Rapid Creek Road (SRCR) is covered by a 1930 recorded easement granting Lawrence County a public highway right-of-way; County plats since the 1970s also treated SRCR as a county road.
- In 1992 Lawrence County granted the United States exclusive easements for the existing road allowing use by the United States and the public for reconstruction and maintenance.
- In 2015 several landowners (including Raymond Oyen) petitioned the Lawrence County Commission for snow removal and maintenance of SRCR; the Commission denied the request.
- Oyen appealed to circuit court; the County moved to dismiss or, alternatively, to join the United States as an indispensable party; the circuit court denied joinder and later ordered the County to maintain the road under SDCL 31-12-26.
- The Supreme Court limited review to the circuit court’s procedural decision refusing to join the United States and reversed, remanding to allow joinder of the United States if feasible or, if not feasible, to decide whether to dismiss under SDCL 15-6-19(b).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the United States is an indispensable party under SDCL 15-6-19 | Oyen: the County is responsible for SRCR and the suit may proceed without the U.S. | County: the U.S. has an interest in the 1992 easement and must be joined or the case cannot proceed | Court: The U.S. is an indispensable party; circuit court erred by ruling without determining joinder feasibility; reversed and remanded |
| Appropriate standard of review for county commission action | Oyen: commission’s action was quasi-judicial; de novo review appropriate | County: contested characterization (implied) | Court: review of joinder decision is de novo; county commission quasi-judicial analysis discussed but joinder question is legal and reviewed de novo |
| Whether circuit court properly adjudicated County’s duty to maintain SRCR on the merits | Oyen: County failed to follow procedures to transfer maintenance; court found County responsible under SDCL 31-12-26 | County: transfer/easement to U.S. affects federal interest and should preclude adjudication without U.S. present | Court: Did not resolve merits; reversed because adjudication occurred without indispensable party and remanded for joinder or dismissal determination |
Key Cases Cited
- South Dakota Department of Game, Fish and Parks v. Troy Township, Day County, 900 N.W.2d 840 (S.D. 2017) (clarifies standard for reviewing county commission quasi-judicial actions)
- Busselman v. Egge, 864 N.W.2d 786 (S.D. 2015) (defines indispensable party as one whose interest prevents final decree without affecting that interest)
- Prentis v. Atlantic Coast Line Co., 211 U.S. 210 (1908) (distinguishes quasi-judicial from legislative administrative acts)
- Coffey v. Coffey, 888 N.W.2d 805 (S.D. 2016) (standard of review: factual findings for clear error, legal conclusions de novo)
- Thieman v. Bohman, 645 N.W.2d 260 (S.D. 2002) (supports definition of indispensable party and joinder principles)