Articles Posted in Civil Rights

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The Supreme Court affirmed Defendant’s conviction of second-degree murder, holding that the circuit court did not err in denying Defendant’s motion to suppress evidence obtained as a result of an investigatory stop. Prior to trial, the circuit court denied Defendant’s motion to suppress the evidence obtained as a result of the stop, concluding that the arresting law enforcement officer had reasonable suspicion to initiate the investigatory stop. The Supreme Court affirmed, holding that the officer’s suspicion was not grounded on a mere hunch, that the officer articulated facts that supported the quantum of suspicion necessary to initiate an investigatory stop, and that, under the totality of the circumstances, the investigatory stop was based on reasonable suspicion within the meaning of the Fourth Amendment. View "State v. Chase" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court entering an amended judgment of conviction ordering Defendant’s sentences to run concurrently to his corresponding federal sentences, holding that Defendant had no Sixth Amendment right to counsel in the circuit court proceeding to correct his sentences. Defendant pleaded guilty to kidnapping and assault. Defendant was sentenced to life imprisonment for the kidnapping and thirty years for the assault. The circuit court ordered the sentences to run consecutively to corresponding federal sentences Defendant had received for the same offenses. The Supreme Court reversed and remanded the case for resentencing, holding that a South Dakota state court may not impose a consecutive sentence in state court when a defendant has been sentenced for the same offenses in federal court. After Defendant was resentenced, he argued that the circuit court’s failure to provide court-appointed counsel in the sentence correction proceeding violated his Sixth Amendment right to counsel. The Supreme Court disagreed, holding that the sentence correction proceeding was not a critical stage in which Defendant had a Sixth Amendment right to court-appointed counsel. View "State v. Red Kettle" on Justia Law

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The Supreme Court dismissed the State’s intermediate appeal challenging the circuit court’s reversal of the magistrate court’s order denying Defendant’s motion to suppress, holding that there was no basis for an appeal to this Court at the present stage of the proceedings. Defendant was charged with driving under the influence of alcohol. Defendant filed a motion to suppress the evidence obtained from the traffic stop, arguing that police officers lacked reasonable suspicion. The magistrate court denied the motion. Defendant was then convicted and sentenced. Defendant appealed, and the circuit court reversed and remanded the judgment. The State petitioned for an intermediate appeal, arguing that the Supreme Court had jurisdiction to hear an appeal under S.D. Codified Laws 23A-32-5. The Supreme Court dismissed the appeal, holding that no appeal can lie from the circuit court’s remand order. View "State v. Sharpfish" on Justia Law

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The Supreme Court reversed Defendant’s conviction and sentence for possessing a controlled substance (methamphetamine), holding that the circuit court erred by denying Defendant’s motion to suppress evidence obtained from an illegal search and seizure. On appeal, Defendant argued that the search of his person violated the United States Constitution’s prohibition against unreasonable searches and seizures. The State did not obtain a warrant to search Defendant but argued that the search was valid as an investigatory stop under Terry v. Ohio, 392 U.S. 1 (1968). The Supreme Court disagreed, holding (1) because the State failed to identify a reasonable suspicion of criminal activity, Defendant’s search and seizure could not be justified under Terry; and (2) the consent exception to the Fourth Amendment’s warrant requirement did not apply in this case. View "State v. Kaline" on Justia Law

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The Supreme Court affirmed the circuit court’s order denying Defendant’s motion to suppress evidence on the grounds that the police officer lacked reasonable suspicion to initiate an investigatory traffic stop and that the search warrant for a blood sample was invalid under South Dakota law. Defendant appealed from an order entering a suspended imposition of sentence after he was found guilty of driving under the influence of alcohol. The Supreme Court affirmed the denial of Defendant’s motion to suppress, holding (1) the circuit court’s finding that the officer observed the vehicle cross the center line provide the officer reasonable suspicion to initiate the stop; and (2) the warrant obtained for Defendant’s blood draw did not violate the Warrants Clause of the South Dakota Constitution. View "State v. Bowers" on Justia Law

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The Supreme Court affirmed the judgment of the habeas court denying Appellant’s petition for a writ of habeas corpus. After a jury trial, Appellant was convicted of second-degree murder and aggravated assault. In his habeas petition, Appellant argued that the circuit court committed errors during the jury selection process that warranted a new trial and that his counsel provided constitutionally ineffective assistance. The habeas court concluded (1) the circuit court committed errors during the jury selection process, but the errors were not structural and Appellant did not prove prejudice; and (2) Appellant failed to prove that counsel was ineffective during the jury selection process. The Supreme Court affirmed, holding (1) the circuit court’s errors during the jury selection process were not structural and were harmless; and (2) Appellant failed to show that he receive ineffective assistance of counsel. View "Miller v. Young" on Justia Law

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The Supreme Court reversed the judgment of the circuit court granting Defendant’s motion to suppress evidence found in the vehicle Defendant was driving, holding that, contrary to the circuit court’s finding, Defendant’s traffic stop was not unlawfully extended. Defendant was indicted on four felony drug charges after controlled substances were found in the vehicle she was driving. The circuit court granted Defendant’s motion to suppress, determining that the officer that stopped the vehicle unlawfully prolonged the traffic stop to question Defendant, conduct standard field sobriety tests, and call for a drug dog without reasonable suspicion of drug activity. The Supreme Court reversed, holding that the officer’s decision to extend the initial traffic stop to question Defendant about drug activity and to conduct the drug dog sniff was supported by reasonable suspicion, and therefore, the traffic stop was not unlawfully extended. View "State v. Barry" on Justia Law

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Under the Fourth Amendment, law enforcement may not require an arrestee to urinate into a specimen container as a search incident to a lawful arrest without a valid warrant. Defendant was convicted and sentenced for unauthorized ingestion of a controlled substance. On appeal, Defendant argued that the circuit court erred by denying his motion to suppress evidence produced through chemical analysis of a urine sample that law enforcement obtained without first obtaining Defendant’s consent or a warrant. After considering an arrestee’s legitimate expectation of privacy and the government’s competing interest in preserving evidence, the Supreme Court agreed, holding (1) law enforcement may not, without a warrant, require an arrestee to provide a urine sample as a search incident to arrest; and (2) therefore, the search in this case was unconstitutional, and the circuit court erred by denying Defendant’s motion to suppress. View "State v. Lar" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree murder and sentencing him to life imprisonment. On appeal, Defendant argued that the circuit court (1) violated his Sixth Amendment right of cross-examination by refusing to admit evidence that Defendant passed a polygraph examination for the purpose of impeaching another witness’s testimony; and (2) improperly admitted character evidence used against him. The Supreme Court held (1) South Dakota’s per se rule against admitting polygraph-test results does not violate the Sixth Amendment, and the circuit court did not abuse its discretion by excluding Defendant’s polygraph evidence; and (2) the circuit court did not err by admitting evidence of Defendant’s sexual liaisons with three other women in the days leading up to the victim’s death. View "State v. Bertram" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court, rendered after a jury trial, convicting Defendant of aggravated assault (domestic) and simple assault (domestic). On appeal, Defendant challenged the circuit court’s admission of evidence of alleged instances of prior domestic abuse and claimed that his trial counsel was constitutionally ineffective. The Supreme Court held (1) the circuit court did not err in admitting the other acts evidence; and (2) counsel was not so ineffective that it deprived Defendant of his constitutional rights to counsel and a fair trial. View "State v. Phillips" on Justia Law