Justia South Dakota Supreme Court Opinion Summaries

Defendant and several others in a group were stopped by South Dakota State University (SDSU) police officers on suspicion of underage consumption and for violating South Dakota’s open container law. Defendant was later convicted of driving under the influence. Defendant appealed, arguing that the circuit court erred in denying her motion to suppress evidence stemming from the stop because law enforcement lacked reasonable suspicion and probable cause to make the stop. The Supreme Court affirmed, holding that, upon consideration of the totality of the circumstances, the SDSU police officers had an individualized, objective, and reasonable basis to believe that Defendant was engaged in criminal activity, and therefore, Defendant’s Fourth Amendment rights were not violated by the stop. View "State v. Meyer" on Justia Law

Defendant pleaded guilty to distribution of a schedule I or II substance and possession of a controlled substance. On the possession charge, the circuit court departed from presumptive probation and imposed a sentence of four years in the penitentiary, with two years suspended. Defendant appealed, arguing that her sentence for a term of imprisonment violated her constitutional right to a jury trial because the court departed from presumptive probation based on facts that were neither found by a jury nor submitted by Defendant. The Supreme Court affirmed, holding that the sentencing court appropriately sentenced Defendant. View "State v. Anderson" on Justia Law

Wharf Resources, Inc., a mining company, terminated Lisa Davis for “disruptive behavior in the workplace.” Several months later, Davis filed a gender discrimination claim and a retaliatory discharge claim with the South Dakota Department of Labor, Division of Human Rights (Department). The Department concluded that there was no probable cause for Davis’s claims. The circuit court affirmed. The Supreme Court affirmed, holding that the circuit court did not err by (1) affirming the Department’s finding of no probable cause; (2) determining that Davis was terminated for permissible factors; and (3) affirming the findings of fact and conclusions of law submitted by the Department. View "Davis v. Wharf Res. (USA), Inc." on Justia Law

After a jury trial, Defendant was found guilty of first-degree rape and sexual contact with a child under the age of sixteen. The Supreme Court affirmed, holding that the circuit court did not err (1) when it denied Defendant’s motion to suppress statements that Defendant claimed were given in violation of Miranda, as Defendant was not in custody for the purposes of Miranda at the time he gave the statements; and (2) when it denied Defendant’s motion for judgment of acquittal, as there was sufficient evidence to support the convictions. View "State v. Deal" on Justia Law

Defendant was twenty-six years old when she was involved in a high-speed pursuit that resulted in life-threatening injuries for a highway patrolman. Defendant pleaded guilty to driving under the influence (DUI) and aggravated assault against a law enforcement officer. Defendant admitted to the part II informations filed for both offenses. Defendant received an aggregate sentence of 42.5 years. Defendant appealed, arguing that her sentence was grossly disproportionate to her crime in violation of the Eighth Amendment. The Supreme Court affirmed, holding that the circumstances of this case failed to suggest gross disproportionality. View "State v. Coleman" on Justia Law

Defendant pleaded guilty to one count of attempted first-degree murder and was sentenced to the maximum term of twenty-five years imprisonment. The Supreme Court affirmed, holding (1) Defendant’s sentence, which was not grossly disproportionate to Defendant’s crime, fell within the constitutional prescriptions of the Eighth Amendment; (2) the inclusion of the federal presentence investigation report in the state presentence investigation report did not violate Defendant’s due process rights; and (3) Defendant was not improperly denied counsel during his interview with court services, as Defendant did not have a Sixth Amendment right to have counsel present at the interview. View "State v. Garreau" on Justia Law

Defendant was convicted of possessing methamphetamine and sentenced to three years imprisonment. Defendant appealed, arguing that the circuit court erred in denying his motion to suppress methamphetamine evidence obtained during a “stop and frisk” because the police officer who initiated the stop lacked a reasonable basis to conclude that Defendant had committed a crime. The Supreme Court reversed, holding that the circuit court erred in denying Defendant’s motion to suppress because the officer did not have a reasonable suspicion of criminal activity, and therefore, the drug evidence was the product of an illegal search. View "State v. Walter" on Justia Law

Plaintiff filed for and obtained an ex parte temporary protection order against Defendant, a former social acquaintance. The Supreme Court affirmed, holding (1) the circuit court’s findings of fact were not clearly erroneous; (2) the circuit court did not abuse its discretion in granting the protection order; (3) Defendant received the notice that due process requires; (4) the circuit court did not abuse its discretion in permitting “other acts” evidence; (5) S.D. Codified Laws 22-19A-1, as applied in this case, was not unconstitutionally vague; and (6) the circuit court did not abuse its discretion in crafting the protection order. View "Donat v. Johnson" on Justia Law

As part of a plea agreement, Defendant pleaded guilty to possession of methamphetamine. After a sentencing hearing, the district court sentenced Defendant to five years in the penitentiary. The Supreme Court affirmed, holding (1) the totality of the circumstances established that Defendant entered his guilty plea voluntarily, knowingly, and intelligently; and (2) Defendant’s constitutional rights were not violated when the circuit court sentenced him to the maximum sentence of five years imprisonment, as the sentence was not grossly disproportionate to the offense committed. View "State v. Moran" on Justia Law

After a jury trial, Defendant was convicted of first-degree rape and sexual contact involving a child. During the trial, the trial judge, on his own initiative, and without a preclosure hearing, closed the courtroom during the victim’s testimony. The jury found Defendant guilty of both charges. After trial, the State moved to supplement the record with facts and reasons for the closure. Defendant moved for a new trial based on the closure. The circuit court granted the State’s motion and denied Defendant’s motion for a new trial. Following a hearing, the court entered findings of fact and conclusions of law supporting closure. The Supreme Court affirmed, holding (1) the circuit court’s error in not having a preclosure hearing to determine whether closure was justified did not require a new trial; and (2) the circuit court made adequate findings demonstrating an overriding interest that was no broader than necessary, considering the alternatives, for courtroom closure during the victim’s testimony. View "State v. Slota" on Justia Law