South Dakota Code § 43-32-28

Retaliatory conduct--Remedies--Attorney's fees
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If the lessor acts in violation of §
43-32-27
, the lessee is entitled to the remedies provided in §
43-32-6
. The court may award the lessee reasonable and customary attorney's fees. A lessee seeking attorney's fees shall provide the court with counsel's verified itemized statement of costs incurred and legal services rendered.

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