Justia South Dakota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of several sex-related crimes, all involving one particular child victim. The Supreme Court affirmed in part, reversed in part, and remanded for a new trial, holding that the trial court (1) did not abuse its discretion by allowing a police detective's opinion on why defendants accused of sex offenses against children do not confess during interrogation; (2) did not abuse its discretion by admitting into evidence the child victim's statements made to a forensic interviewer; and (3) abused its discretion in allowing an expert witness for the State to give a medical diagnosis of "child sexual abuse."View "State v. Buchholtz" on Justia Law

After a jury trial, Defendant was found guilty of aggravated assault. On appeal, Defendant argued that the State’s peremptory strike of a Native American veniremember was racially motivated. The Supreme Court held that the circuit court had failed to address third step of the Batson v. Kentucky analysis and remanded with directions for the court to determine whether Defendant satisfied his burden to prove the State’s peremptory strike was racially motivated. On remand, the circuit court performed the third step and concluded that the State’s strike was not based on purposeful racial discrimination. The Supreme Court affirmed after a de novo review, holding that Defendant failed to carry his burden of proving purposeful racial discrimination. View "State v. Scott" on Justia Law

Joseph Burkett was arrested by Officer Justin Lux after the officer approached the Burkett’s vehicle, which was stopped in the middle of the road, and concluded that Burkett had been driving under the influence. A jury found Burkett guilty of DUI. Based on Burkett’s two prior DUI convictions within ten years of the current offense, Burkett was sentenced to a Class 6 felony. The Supreme Court affirmed, holding (1) the circuit court’s use of Burkett’s prior DUI convictions for sentencing enhancement purposes did not violate Burkett’s right to due process; (2) there was sufficient evidence to support the jury’s verdict; and (3) the circuit court did not err in denying Burkett’s motion to suppress based on Officer's Lux’s stop of Burkett, as the officer's decision to stop Burkett was reasonable. View "State v. Burkett" on Justia Law

In 2002, Petitioner, an inmate serving a fifteen-year sentence, pleaded guilty to possession of an unauthorized article by an inmate. Petitioner did not file a direct appeal. In 2010, Petitioner filed a petition for writ of habeas corpus, alleging several constitutional violations, including ineffective assistance of trial counsel for counsel's failure to preserve Petitioner's right to appeal. After an evidentiary hearing, the habeas court denied the petition based on prejudice to the State caused by Petitioner's failure to timely file his petition. The Supreme Court affirmed, holding that Petitioner failed to rebut the statutory presumption of prejudice to the State in its ability to respond to the application due to Petitioner's failure to timely file the application.View "Davis v. Weber" on Justia Law

After a jury trial in 1995, Petitioner was convicted of child rape, sexual contact, disseminating harmful material to minors, and indecent exposure. Petitioner was acquitted in the same trial of raping two other children. Approximately a decade later, in a habeas corpus proceeding, the counseling records for the child Petitioner was convicted of raping were first disclosed. The habeas court denied Petitioner's amended petition for a writ of habeas corpus and Petitioner's amended motion for a certificate of probable cause, concluding that Petitioner had not shown "a reasonable probability that the specific timing of the disclosure would have created reasonable doubt in the jurors' minds considering the entire record." The Supreme Court issued a certificate of probable cause, resulting in this appeal. The Supreme Court affirmed, holding that Petitioner was not denied due process because of the State's failure to produce the counseling records, as there was no reasonable probability that, had the evidence been timely disclosed to the defense, the result of Petitioner's trial would have been different.View "Thompson v. Weber" on Justia Law

After a jury trial, Defendant was found guilty of three counts of distribution of a controlled drug or substance and three counts of possession of a controlled drug or substance. The Supreme Court affirmed the convictions, holding that the circuit court (1) did not violate Defendant’s due process rights in denying his motion to suppress an in-court identification stemming from an improper photo lineup; (2) did not err in refusing Defendant’s proposed jury instruction regarding cross-racial identification; and (3) did not err in denying Defendant’s motion for judgment of acquittal, as there was sufficient evidence to support the jury verdict. View "State v. Chuol" on Justia Law

After a jury trial, Appellant was convicted of driving under the influence of alcohol (DUI) and driving while having a 0.08 percent or more by weight of alcohol in the blood. Appellant appealed in part the trial court's admission of certain testimony regarding the Horizontal Gaze Nystagmus (HGN) test, which the arresting officer conducted during the stop of Appellant's vehicle. The Supreme Court affirmed the convictions, holding (1) even if the trial court erred in allowing the arresting officer to testify about the reliability of HGN testing and the correlation between an individual's performance on an HGN test and the individual's blood alcohol content, the error was harmless; and (2) the trial court did not err in denying Appellant's motion for a judgment of acquittal because there was sufficient evidence from which the jury could have convicted Appellant of DUI beyond a reasonable doubt.View "State v. Yuel" on Justia Law

Defendant was charged with driving under the influence of alcohol (DUI). A part two information alleged that Defendant had two previous DUI convictions within the last ten years, including one in 2011. Defendant filed a motion to strike the 2011 conviction from the part two information, claiming that his guilty plea was invalid because he was not fully advised that he would waive his right to a jury trial, right to confrontation, and right against self-incrimination. The circuit court agreed with Defendant and ordered that the 2011 conviction be stricken from the part two information. The Supreme Court reversed, holding that the circuit court erred when it struck Defendant's 2011 conviction from the part two information, as the record affirmatively showed that Defendant was fully advised of his rights under Boykin v. Alabama during his 2011 conviction and intelligently and voluntarily waived those rights.View "State v. Smith" on Justia Law

Defendant was charged with possession of cocaine, possession of marijuana, and ingestion of marijuana. Defendant moved to suppress the evidence as the fruit of an illegal search of his hotel room. The trial court granted the motion with respect to the drugs seized during the initial illegal search but denied the motion with respect to evidence gathered during a subsequent call to the hotel. After a trial, Defendant was convicted as charged. The Supreme Court affirmed, holding the trial court did not err in denying in part Defendant's motion to suppress evidence, as the second call to police constituted an independent source of evidence against Defendant and that the evidence obtained thereby bore no causal connection to the evidence illegally seized in Defendant's hotel room. View "State v. Heney" on Justia Law

Defendant, who was fifteen years old and a native Spanish speaker, was transported to the police department for questioning in connection with the death of Jasmine Guevara. During her questioning by police, Defendant confessed to the murder. Defendant moved to suppress her confession, arguing that she did not voluntarily, knowingly, and intelligently waive her Miranda rights. The juvenile court denied the motion. The case was then transferred to adult court in the First Judicial Circuit. The trial court reopened the motion to suppress and granted the motion, concluding that Defendant made her statements voluntarily but did not knowingly and intelligently waive her rights. The State appealed. The Supreme Court reversed, holding that the trial court erred in suppressing Defendant’s confession where the State met its burden to show more likely than not that Defendant’s waiver of her Miranda rights was “with a full awareness of both the nature of the right being abandoned and the consequences of the decision to abandon it.” View "State v. Diaz" on Justia Law