Estate of Sanborn v. Peterson

2026 S.D. 14
CourtSouth Dakota Supreme Court
DecidedMarch 4, 2026
Docket30857, 30872
StatusPublished

This text of 2026 S.D. 14 (Estate of Sanborn v. Peterson) 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
Estate of Sanborn v. Peterson, 2026 S.D. 14 (S.D. 2026).

Opinion

#30857, #30872-a-MES 2026 S.D. 14

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

ESTATE OF KYLEE L. SANBORN, by and through its Personal Representative, Sarah C. Sanborn, and ESTATE OF JAYNA R. SANBORN, by and through its Personal Representative, Sarah C. Sanborn, Plaintiffs and Appellants,

v.

MARK PETERSON, TODD HERTEL, BRAD LETCHER, DAN MARTEL, MICHAEL HIEB, and TERENCE PECK, Defendants and Appellees.

APPEAL FROM THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT BEADLE COUNTY, SOUTH DAKOTA

THE HONORABLE KENT A. SHELTON Judge

JOHN W. BURKE of Thomas Braun Bernard & Burke, LLP Rapid City, South Dakota

ARGUED OCTOBER 8, 2025 OPINION FILED 03/04/26 ****

MICHAEL J. SCHAFFER PAUL H. LINDE of Schaffer Law Office, Prof. LLC Sioux Falls, South Dakota Attorneys for plaintiffs and appellants.

JUSTIN L. BELL DOUGLAS A. ABRAHAM ROBERT B. ANDERSON of May Adam Gerdes & Thompson, LLP Pierre, South Dakota Attorneys for defendants and appellees. #30857, #30872

SALTER, Justice

[¶1.] Following the death of her two daughters in a car accident that

occurred along U.S. Highway 281, Sarah Sanborn brought suit against several

South Dakota Department of Transportation (DOT) employees in both their

individual and official capacities. Sarah claims that the fatal accident resulted from

the DOT employees’ negligent failure to maintain and repair the adjacent gravel

shoulder in compliance with governing standards. The DOT employees moved for

summary judgment, asserting Sarah’s claims were barred by sovereign immunity

and the public duty doctrine. The circuit court granted the defendants’ motion for

summary judgment drawing on both arguments. The court determined that

sovereign immunity barred Sarah’s official capacity claims but not the individual

capacity ones, which the circuit court ultimately found to be barred by the public

duty doctrine. Sarah appeals the public duty decision, and the defendants seek

review of the court’s decision denying summary judgment of the individual capacity

claims based on sovereign immunity. We affirm the circuit court’s grant of

summary judgment on the individual capacity claims, but we do so under the

doctrine of sovereign immunity.

Factual and Procedural History

[¶2.] On November 24, 2019, Kylee Sanborn and her older sister Jayna were

tragically killed in an automobile crash on U.S. Highway 281 near Bonilla in Beadle

County. As the girls approached a slight curve in the road, their car drifted to the

right, across the white fog line and on to the gravel shoulder, which was five to six

inches below the paved roadway.

-1- #30857, #30872

[¶3.] Kylee was driving, and in the moments that followed, she attempted to

steer the car left, back on to the roadway from the lower shoulder, resulting in an

overcorrection that caused the car to veer into the southbound lane and into

oncoming traffic. After narrowly missing a fuel truck, Kylee and Jayna collided

head on with a pickup.

[¶4.] Following the accident, Sarah brought this wrongful death and

survivor action as the personal representative of her daughters’ estates. The

amended complaint named as defendants six DOT employees in both their official

and individual capacities: (1) Mark Peterson—the region engineer for the DOT’s

Aberdeen region, (2) Todd Hertel—the Aberdeen region’s operations engineer, (3)

Dan Martel—the Aberdeen region’s traffic engineering supervisor, (4) Brad

Letcher—a DOT area engineer, (5) Michael Hieb—a DOT highway maintenance

supervisor from 2010 through 2021, and (6) Terence Peck—a DOT lead

maintenance worker.

[¶5.] In an amended complaint, Sarah alleges that “[b]ecause Highway 281

is part of South Dakota’s state trunk [highway] system, the Defendants are

responsible for the construction, maintenance, repair, and condition of Highway

281, including, but not limited to, the shoulders . . . .” She asserts that the

defendants had both statutory and common law duties to maintain and repair the

shoulder along Highway 281, alleging further that these duties are specifically

defined in the DOT’s maintenance manual, which contains the policies, standards,

and guidelines for highway maintenance.

-2- #30857, #30872

[¶6.] The manual in effect at the time of the accident (November 2019)

included a policy letter titled, “Policy Number: OM-2002-09,” which required

“[e]xisting gravel shoulders” to be maintained in their “design condition.” Because

Highway 281 was designed and constructed with a gravel shoulder that was flush

with the paved portion of the roadway, Sarah alleges the defendants breached a

ministerial duty by failing to maintain a flush shoulder.

[¶7.] The policy letter also incorporated specific performance standards,

such as Performance Standard Function 2158, which relates specifically to gravel

shoulder maintenance and repair. Drawing on these performance standards, Sarah

alleges that Highway 281’s gravel shoulder should have been repaired “when the

shoulder surface [sank] more than one and a half inches lower than the pavement,

and in isolated areas where gravel ha[d] been lost.”

[¶8.] Highway 281 is also part of the National Highway System and subject

to a stewardship agreement between the DOT and the Federal Highway

Administration (FHWA). Sarah alleges that this obligated the DOT “to follow the

American Association of State Highway and Transportation Officials (‘AASHTO’)

standard,” which also requires “shoulders to be maintained flush with the

pavement.” Sarah asserts that under its federal stewardship agreement, the DOT

agreed to abide by “the control documents for the design of highways, including the

policy on Geometric Design of Highways and Streets (commonly referred to as the

‘Green Book’), the Roadside Design Guide, and other standards.”

[¶9.] The defendants moved for summary judgment asserting first that

sovereign immunity bars Sarah’s claims because the governing standards for

-3- #30857, #30872

highway maintenance and repair that she identifies impose discretionary, not

ministerial, duties. As such, the defendants contend the State has not waived

sovereign immunity for the conduct underlying her claims.

[¶10.] Under a separate summary judgment argument, the defendants assert

that the public duty doctrine precludes Sarah’s claims. They asserted that highway

maintenance and repair are public safety functions that implicate public duties to

the motoring public generally—not private actionable duties.

[¶11.] The circuit court granted the defendants’ motion in a mixed decision.

The court concluded that the defendants were entitled to sovereign immunity in

their official but not individual capacities. The court reasoned that Policy Number

OM-2002-09 created a ministerial duty for the DOT to maintain gravel shoulders

“in accordance with the[ir] initial design plan[s].” The court did, however, grant

complete summary judgment in the defendants’ favor after concluding that highway

maintenance and repair is “an act of public safety” and that Sarah’s claims are

therefore barred by “the public duty doctrine[, which] extends to a government

employee being sued on an issue involving law enforcement or public safety.”

[¶12.] Sarah appeals the circuit court’s application of the public duty

doctrine. And by notice of review, the defendants seek reversal of the court’s

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Estate of Sanborn v. Peterson
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2026 S.D. 14, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-sanborn-v-peterson-sd-2026.