Arrowsmith v. Odle

2025 S.D. 70
CourtSouth Dakota Supreme Court
DecidedDecember 17, 2025
Docket31024
StatusPublished

This text of 2025 S.D. 70 (Arrowsmith v. Odle) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arrowsmith v. Odle, 2025 S.D. 70 (S.D. 2025).

Opinion

#31024-r-JMK 2025 S.D. 70

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

RYAN SCOTT ARROWSMITH, Plaintiff and Appellant,

v.

DEVIN MATTHEW ODLE, Defendant and Appellee.

APPEAL FROM THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT MEADE COUNTY, SOUTH DAKOTA

THE HONORABLE JOHN H. FITZGERALD Judge

ERIN SCHOENBECK BYRE JAMI J. BISHOP of Johnson, Janklow & Abdallah, LLP Sioux Falls, South Dakota Attorneys for plaintiff and appellant.

CASSIDY M. STALLEY of Nooney & Solay, LLP Rapid City, South Dakota Attorneys for defendant and appellee.

CONSIDERED ON BRIEFS NOVEMBER 17, 2025 OPINION FILED 12/17/25 #31024

KERN, Retired Justice

[¶1.] Plaintiff Ryan Arrowsmith and Defendant Devin Odle were involved in

a collision in 2017 at the Sturgis Motorcycle Rally. Arrowsmith, who was riding his

motorcycle at the time of the accident, alleged Odle pulled his vehicle out of a

parking lot directly in front of Arrowsmith’s motorcycle, causing a collision.

Arrowsmith suffered injuries and sued Odle in 2020 for damages. After initial

discussions, Arrowsmith granted Odle’s insurance carrier an open-ended extension

to file an answer due to the nature of Arrowsmith’s ongoing treatment for his

injuries and the uncertainty of his recovery. The Meade County clerk of courts

issued notices of intent to dismiss the case in 2021 and 2022 for inactivity in the

file. Arrowsmith objected to each notice and the court dismissed the notices. The

clerk of courts issued a third notice of intent to dismiss in June 2024, and

Arrowsmith again objected. Odle secured representation in August 2024,

whereupon Odle’s counsel discussed the case with Arrowsmith’s counsel and

reaffirmed the open-ended extension agreement. Two months later, Odle’s counsel

filed a motion to dismiss for failure to prosecute. After a hearing on the matter, the

circuit court granted Odle’s motion to dismiss with prejudice under SDCL 15-11-11

and SDCL 15-6-41(b). Arrowsmith appeals. We reverse.

Factual and Procedural History

[¶2.] Plaintiff Ryan Arrowsmith resides in British Colombia, Canada, and

was attending the Motorcycle Rally1 in Sturgis, South Dakota, on August 11, 2017.

1. Held in Sturgis, South Dakota, the Sturgis Motorcycle Rally is an annual event which began in 1938 and has now grown to be one of the oldest and (continued . . .) -1- #31024

While riding his motorcycle, he collided with Defendant Devin Odle’s vehicle when

Odle pulled out of a parking lot directly into Arrowsmith’s path. Arrowsmith

suffered serious injuries as a result of the crash. Arrowsmith filed a complaint

against Odle on July 23, 2020, alleging claims of negligence and negligence per se

arising from the accident. Five days later, Odle was personally served with the

complaint and summons.

[¶3.] Shortly after the complaint was filed, on August 20, 2020, Odle’s

insurance carrier, AAA Insurance, contacted Arrowsmith’s counsel to discuss the

case. Arrowsmith’s counsel advised AAA that his client’s recovery was ongoing, and

that further surgery was required. Because it was difficult to ascertain the value of

Arrowsmith’s claim at the time, counsel granted AAA an open extension of time to

obtain counsel and file an answer. Arrowsmith’s counsel confirmed the extension in

an e-mail dated August 20, 2020. The purpose of this extension was presumably to

allow for “maximum recovery information” before resuming litigation, as

Arrowsmith’s counsel believed he was “not in a position to properly evaluate the

value of the claim because of the uncertain nature of future treatment.”

[¶4.] A little more than a year later, on September 22, 2021, the Meade

County clerk of courts issued a notice of intent to dismiss the action due to absence

of file activity for more than one year. The next day, Arrowsmith’s counsel objected

to the notice and explained that at the time of service, he had a conversation with

________________________ (. . . continued) largest motorcycle rallies in the world. Travel South Dakota, Sturgis Motorcycle Rally, https://www.travelsouthdakota.com/trip-ideas/sturgis- motorcycle-rally (last visited Dec. 10, 2025). In recent years, the rally has drawn crowds of more than 600,000. Id.

-2- #31024

AAA, whereby he “granted AAA an open extension of time to obtain counsel and

answer the Complaint” because “Plaintiff’s recovery was ongoing, [and] it was

difficult at this that [sic] time to ascertain an appropriate valuation of the claim.”

[¶5.] According to Arrowsmith’s counsel, the obstacles to ascertaining the

extent of Arrowsmith’s damages included the fact that he resided in Canada, that

he reinjured his wrist and required further treatment, and that his medical

providers and subrogation lienholders resided in Canada. Arrowsmith’s counsel

reassured the court that at the time of the objection to the 2021 notice, Arrowsmith

appeared “to have reached his maximum recovery” and that counsel was “in the

process of obtaining subrogation information from several Canadian providers.”

Counsel further asserted Arrowsmith would “be in a position to discuss potential

settlement of this matter with AAA” once he obtained all the relevant subrogation

information.

[¶6.] The second notice of intent to dismiss the action was issued on

November 23, 2022. Arrowsmith’s counsel again objected, and his response closely

resembled his September 2021 objection but contained additional information.

Arrowsmith’s counsel informed the court that he had “been in touch with AAA to

provide updates on Plaintiff’s ongoing care and to assure AAA that the open

extension of time to answer the Complaint remains in effect.” He addressed the

statement he made in September 2021 that Arrowsmith had reached his maximum

recovery and stated, “Since then, unfortunately, Plaintiff has experienced several

setbacks with respect to his injuries.” Counsel again assured the court that he was

-3- #31024

awaiting information from Canadian providers, and that settlement discussions

would commence once this information was “in hand.”

[¶7.] The third notice of intent to dismiss—which is the subject of this

appeal—was issued by the clerk of courts on June 21, 2024. One week later,

Arrowsmith’s counsel filed a nearly identical objection to his 2021 and 2022

pleadings, but this objection also noted that Arrowsmith had “recently been

evaluated regarding his disability and employability prospects and his impairment

rating” and that counsel could “potentially finalize settlement” once he had this

information. Aside from the three notices and Arrowsmith’s corresponding

objections, the record contains no evidence of additional activity.

[¶8.] Odle obtained counsel in August 2024. Arrowsmith’s counsel was first

notified that Odle was represented when Odle’s counsel emailed him on August 1,

2024. During the hearing on the motion to dismiss, both attorneys confirmed that

during the August 1 communications, they discussed and reaffirmed the open-ended

extension agreement that Arrowsmith originally granted to AAA. Odle’s counsel

indicated there were no emails or any letters explaining what was intended by the

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Bluebook (online)
2025 S.D. 70, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arrowsmith-v-odle-sd-2025.