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Americana Healthcare Center v. Randall

Supreme Court of South Dakota
513 N.W.2d 566 (S.D. 1994)


Facts

Robert Randall (defendant) was the only child of Juanita Randall. When Robert’s father passed away, Juanita established an irrevocable trust and named Robert as the trustee. Juanita also gave Robert power of attorney over her checking account. At the time, Juanita was 92 years old, and Robert was an adult. Robert lived in Washington, D.C., while Juanita lived in South Dakota. Juanita was in an accident and needed full-time care. With Robert’s help, Juanita was admitted to a nursing home owned by Americana Healthcare Center (Americana) (plaintiff). Although Juanita had a house and mutual funds in the trust, she had otherwise limited income and was considered indigent. Americana sent bills for Juanita’s care to Robert, but Robert did not pay the bills. Juanita passed away while residing in Americana’s nursing home. Americana brought suit against Robert, seeking to recover for the unpaid bills. Americana based the suit on a South Dakota law that required adult children to assist in the financial support of their indigent, aged parents if the children had the financial ability to do so. Robert argued that the statute violated his rights to equal protection and due process. In terms of due process, Robert claimed that because Washington, D.C., did not have a similar law, the court could not apply the South Dakota law to Robert, a resident of Washington, D.C. The trial court ruled in Americana’s favor. Robert appealed.

Rule of Law

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Issue

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Holding and Reasoning (Amundson, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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