The South Dakota Supreme Court issued an opinion in *Trumble v. Trumble* (S.D. 2025), addressing complex issues of property division and disclosure obligations when marital assets are destroyed during divorce proceedings. The case centers on a Canadian residential property that burned down while the couple's divorce was pending and the wife's failure to fully disclose insurance coverage.
Jacqueline M. Trumble filed for divorce against her husband Eric Trumble in Minnehaha County Circuit Court. During the proceedings, the couple owned a large residential property in Canada that became central to their property division discussions. The Canadian property burned to the ground while their divorce case was still pending, creating unique legal challenges regarding the division of insurance proceeds.
During discovery, Jacqueline disclosed an insurance policy with a $2 million Canadian dollar coverage limit for the property. She represented to the court and her husband that this was the sole insurance policy covering the premises. Based on this disclosure, the parties entered into a stipulation and agreement that entitled Jacqueline to receive the Canadian property and all related insurance policy proceeds upon divorce.
The circuit court, presided over by Judge John Pekas, entered a divorce decree based on irreconcilable differences and incorporated the parties' agreement into the final order. The decree appeared to resolve all property division issues, including the insurance proceeds from the destroyed Canadian property.
However, nearly seven months after the divorce was finalized, Eric discovered that Jacqueline was actually receiving $4 million Canadian dollars in insurance proceeds, not the $2 million originally disclosed during the divorce proceedings. This represented a significant discrepancy that doubled the actual value of the insurance recovery.
Upon learning of the additional $2 million in insurance proceeds, Eric filed a motion for relief from the court's order. His motion was based on the ground that Jacqueline had failed to make full disclosure of the insurance coverage during the divorce proceedings, which he argued materially affected the property division agreement.
The case raises important questions about disclosure obligations during divorce proceedings, particularly when dealing with cross-border property ownership and insurance policies. South Dakota, like most states, requires full financial disclosure during divorce proceedings to ensure equitable property division.
The discovery of the additional insurance proceeds suggests that either Jacqueline failed to adequately investigate her insurance coverage or deliberately withheld information about the full extent of the policy benefits. Either scenario could provide grounds for relief from the divorce decree under South Dakota law.
Courts have authority to grant relief from judgments in cases involving fraud, misrepresentation, or other misconduct that affects the integrity of the judicial process. When a party fails to disclose material assets during divorce proceedings, it can undermine the entire basis for the property division agreement.
The case also highlights challenges that arise when marital property is located in foreign jurisdictions. Insurance policies on Canadian property may have different terms, conditions, and coverage limits than comparable U.S. policies. This can create additional complexity in determining the true value of marital assets.
The involvement of prominent South Dakota law firms on both sides underscores the significance of the case. Jacqueline was represented by Alex S. Halbach and Robert D. Trzynka of Halbach Szwarc Law Firm, while Eric was represented by A. Russell Janklow and Erin Schoenbeck Byre of Johnson, Janklow & Abdallah, LLP.
The Supreme Court's decision in this case will likely provide guidance for future divorce cases involving undisclosed assets or insurance proceeds. It may also clarify the standards courts should apply when determining whether to grant relief from divorce decrees based on allegations of inadequate disclosure.
The timing of the property destruction during the divorce proceedings created a unique factual scenario. When marital property is destroyed during litigation, courts must determine how to value and divide the resulting insurance proceeds. This requires careful analysis of insurance policies and coverage limits.
The case was considered on briefs submitted August 26, 2025, and the opinion was filed Nov. 12, 2025. Justice Kern authored the court's opinion, though the full text of the court's reasoning and holding was not available in the materials reviewed.
This case serves as a reminder of the importance of complete financial disclosure during divorce proceedings and the potential consequences of failing to reveal material information about marital assets. The outcome may influence how courts handle similar cases involving cross-border property and insurance issues in future divorce litigation.