Wetch v. Midcontinent Media, Inc.

CourtSouth Dakota Supreme Court
DecidedMay 27, 2026
Docket31059, 31060
StatusPublished

This text of Wetch v. Midcontinent Media, Inc. (Wetch v. Midcontinent Media, Inc.) 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
Wetch v. Midcontinent Media, Inc., (S.D. 2026).

Opinion

#31059, #31060-vacate & dismiss-MES 2026 S.D. 34

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

DAVID V. WETCH, Claimant and Appellant,

v.

MIDCONTINENT MEDIA, INC. and CRUM & FORSTER COMMERCIAL INSURANCE, Employer/Insurer and Appellees.

APPEAL FROM THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT HUGHES COUNTY, SOUTH DAKOTA

THE HONORABLE MARGO NORTHRUP Judge

NATHAN R. OVIATT G. VERNE GOODSELL SAMUEL J. STROMMEN of Goodsell Oviatt, LLP Rapid City, South Dakota Attorneys for claimant and appellant.

THOMAS J. VON WALD of Boyce Law Firm, LLP Sioux Falls, South Dakota

BARTHOLOMEW L. MCLEAY SUZANNE M. SHEHAN-AMES of Kutak Rock LLP Omaha, Nebraska Attorneys for employer/insurer and appellees.

ARGUED FEBRUARY 10, 2026 OPINION FILED 05/27/26 #31059, #31060

SALTER, Justice

[¶1.] David Wetch sustained a compensable work-related injury in 1991 and

received ongoing medical benefits as a result of a stipulated settlement that the

Department of Labor (Department) had approved. Wetch fell down a set of stairs at

his apartment in 2010, which resulted in an increased need for medical care. After

learning of the fall years later, his original employer and its workers’ compensation

carrier asked the Department to review Wetch’s medical payments, alleging Wetch

had experienced a change in condition and that the 2010 fall—not the 1991 work-

related injury—accounted for his need for treatment. The Department agreed and

concluded that Wetch’s change in condition warranted termination or reduction in

his workers’ compensation benefits, but it did not determine which one. The circuit

court affirmed the Department, and Wetch has again appealed.

[¶2.] Following oral argument, we ordered supplemental briefing on

whether the Department’s order was final. We now conclude it was not and dismiss

the appeal and vacate the circuit court’s order.

Factual and Procedural Background

[¶3.] In July 1991, Wetch sustained a serious spinal cord injury while

working for Midcontinent Media, Inc., which was enrolled for workers’

compensation insurance through Crum & Forster Commercial Insurance

(collectively, the Insurer). After receiving medical treatment, including a spinal

fusion operation, Wetch petitioned the Department for workers’ compensation

benefits. He later entered into a stipulated agreement with the Insurer under

which the parties agreed Wetch was permanently and totally disabled. The

-1- #31059, #31060

Department approved the agreement in 1994, and despite setbacks, Wetch’s need

for medical treatment abated considerably over the years that followed. In fact,

between late 2006 through 2010, Wetch did not submit any claims for

reimbursement of medical expenses to the Insurer.

[¶4.] Then, in 2010, Wetch fell down a set of stairs at his apartment

building and sustained head and neck injuries. He did not advise the Insurer of

this fall. Wetch’s requests for medical benefits increased noticeably after the 2010

fall, and his related efforts to obtain them ultimately led him to file another petition

with the Department in 2014.

[¶5.] The Department ordered certain medical payments for Wetch’s care in

a series of four partial summary judgment orders entered from 2015 to 2018. The

lengthy procedural record reveals multiple efforts by Wetch seeking to enforce these

orders, including contempt proceedings before a circuit court judge in 2016 and

2018, both of which were ultimately dismissed as moot after the Insurer agreed to

pay medical benefits.

[¶6.] The Insurer became aware of Wetch’s 2010 fall years later during the

course of discovery in a bad faith civil action commenced by Wetch in federal court.

But the Insurer did not, on its own volition, seek to avoid liability for the benefits

paid after the 2010 fall by seeking a review under SDCL 62-7-33, which authorizes

the Department to review workers’ compensation payments “made or to be made”

and end, diminish, increase, or award payments “if the department finds that a

change in the condition of the employee warrants such action.”

-2- #31059, #31060

[¶7.] Instead, the federal district court ordered the Insurer to return to the

Department and seek relief under SDCL 62-7-33 and SDCL 62-4-47, which allows

workers’ compensation payors to avoid liability when an employee has acted

fraudulently. The district court stayed the bad faith action “until defendants obtain

a final decision on Mr. Wetch’s benefits from the [Department] and state courts

have exercised their powers of appellate review.” Wetch v. Crum & Forster Com.

Ins., 17-CV-5033, 2020 WL 898357, *28 (D.S.D. Feb. 25, 2020). In the district

court’s view, the Insurer had “been avoiding returning to the [Department] and

seeking to reopen Mr. Wetch’s earlier claims . . . either as fraudulent (for failing to

disclose the 2010 fall) under § 62-4-47 or as neither reasonable nor necessary

medical care (because of the intervening 2010 fall) under § 62-7-33.” Id. at *27.

[¶8.] The Insurer complied by filing a March 2020 written request with the

Department in the same file designated for Wetch’s 2014 petition. Its request

stated that it “has reason to believe the April 2010 fall, and not [Claimant’s] 1991

work injury, caused a change of condition and was the cause of Claimant’s need for

subsequent neurosurgical treatment, physical neuromuscular deterioration, and

progressive neuromuscular decline on and after April 2010.” In what was

essentially a prayer for relief, the Insurer concluded by “requesting the Department

grant its request to review medical care/payments pursuant to SDCL 62-7-33 and

for an investigation and hearing pursuant to SDCL 62-4-[4]7 and 62-4-48.” For

reasons that are not clear in the record, the Department subsequently assigned the

Insurer’s request a new 2020 file number.

-3- #31059, #31060

[¶9.] The Department conducted a four-day evidentiary hearing on the

Insurer’s written request and issued a decision and corresponding order in April

2024. The Department determined that Wetch did not commit fraud by failing to

disclose the 2010 fall, but concluded a “change in condition . . . has occurred

warranting this determination by the Department that payment(s) made for the

benefit of Wetch should be ended or diminished pursuant to SDCL 62-7-33.”

Critically, however, the Department’s order did not actually determine whether

Wetch’s benefits should either be ended or diminished, and if the latter, by what

amount.

[¶10.] Nevertheless, the Insurer filed a motion for vacatur in Wetch’s 2014

Department file, invoking the Department’s favorable (but seemingly incomplete)

determination that Wetch had experienced a change in condition. The Insurer

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