The South Dakota Supreme Court has issued an opinion in *Arrowsmith v. Odle*, a case stemming from a motorcycle collision during the 2017 Sturgis Motorcycle Rally that raised questions about court procedures and case management.
The collision occurred when Ryan Scott Arrowsmith was riding his motorcycle and Devin Matthew Odle allegedly pulled his vehicle out of a parking lot directly in front of Arrowsmith's motorcycle, causing an accident. Arrowsmith suffered injuries in the crash and filed a lawsuit against Odle in 2020 seeking damages.
The case took an unusual procedural path due to ongoing settlement discussions and the nature of Arrowsmith's continuing medical treatment. After initial discussions between the parties, Arrowsmith granted Odle's insurance carrier an open-ended extension to file an answer to the lawsuit. This extension was granted because of the uncertainty surrounding Arrowsmith's recovery and his ongoing treatment for injuries sustained in the collision.
The extended timeline led to complications with court administrative procedures. The Meade County clerk of courts issued notices of intent to dismiss the case for inactivity in both 2021 and 2022. In each instance, Arrowsmith objected to the dismissal notices, and the circuit court dismissed the notices, allowing the case to continue.
The procedural issues persisted when the clerk of courts issued a third notice of intent to dismiss in June 2024, again citing inactivity in the case file. Arrowsmith once more objected to this dismissal notice. The situation changed significantly in August 2024 when Odle secured legal representation through Cassidy M. Stalley of Nooney & Solay, LLP in Rapid City.
Once Odle obtained counsel, his attorney engaged in discussions with Arrowsmith's legal team, represented by Erin Schoenbeck Byre and Jami J. Bishop of Johnson, Janklow & Abdallah, LLP from Sioux Falls. The record indicates that Odle's counsel reaffirmed certain positions during these discussions, though the complete details of the settlement negotiations and legal arguments are not fully detailed in the available portion of the opinion.
The case was appealed from the Circuit Court of the Fourth Judicial Circuit in Meade County, where it was originally heard before the Honorable John H. Fitzgerald. The appeal reached the South Dakota Supreme Court, which considered the matter on briefs submitted in November 2025.
Retired Justice Kern authored the opinion for the high court, which was filed on Dec. 17, 2025. The opinion was designated as 2025 S.D. 70 in the court's citation system and assigned case number #31024-r-JMK.
The case highlights several important aspects of South Dakota civil procedure, particularly regarding case management when parties are engaged in ongoing settlement negotiations. The multiple notices of intent to dismiss for inactivity demonstrate the tension between administrative efficiency in managing court dockets and the practical realities of complex personal injury cases where medical treatment and recovery timelines can extend over several years.
The extended timeline from the 2017 collision to the 2025 Supreme Court opinion also illustrates the challenges faced in motorcycle accident cases, where injuries may require prolonged treatment and the full extent of damages may not be immediately apparent. This uncertainty often necessitates extended discovery periods and settlement negotiations.
Motorcycle accidents during the annual Sturgis Motorcycle Rally present particular challenges for the South Dakota court system, as the event draws hundreds of thousands of visitors to the Black Hills region each August. The rally, which has been held annually since 1938, brings together motorcycle enthusiasts from across the country, creating unique traffic patterns and increased collision risks during the event period.
The involvement of insurance carriers in the procedural aspects of the case also demonstrates the complex interplay between civil litigation and insurance coverage in motor vehicle accidents. The open-ended extension granted to Odle's insurance carrier reflects common practices in personal injury cases where the full extent of damages may not be immediately known.
The case serves as a reminder of the importance of proper case management and communication between parties and the court system. While the full implications of the Supreme Court's ruling are not detailed in the available excerpt, the decision likely provides guidance on procedural requirements and case dismissal standards in South Dakota civil courts.
The opinion will be significant for practitioners handling similar motor vehicle accident cases in South Dakota, particularly those involving extended settlement negotiations and medical treatment periods that may trigger administrative dismissal procedures.