Under South Dakota law, if a court finds that any party has willfully violated or willfully failed to comply with any provisions of a custody or visitation decree, the court shall impose appropriate sanctions to punish the offender or to compel the offender to comply with the terms of the custody or visitation decree.
Sanctions which the court may, in its discretion, order include:
(1) To require the offender to provide the other party with make up time with the child equal to the time missed with the child, due to the offender's noncompliance;
(2) To require the offender to pay, to the other party, court costs and reasonable attorney's fees incurred as a result of the noncompliance;
(3) To require the offender to pay a civil penalty of not more than the sum of one thousand dollars;
(4) To require the offender to participate satisfactorily in counseling or parent education classes;
(5) To require the offender to post bond or other security with the court conditional upon future compliance with the terms of the custody or visitation decree or any ancillary court order; or
(6) To impose a jail sentence on the offender of not more than three days.
