Justia South Dakota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first-degree kidnapping, second-degree rape, and aggravated assault. The Supreme Court affirmed Defendant's convictions. Defendant subsequently filed an amended application for writ of habeas corpus, alleging that he was denied effective assistance of counsel, a fair trial, and due process of law. The habeas court denied the writ. The Supreme Court affirmed, holding (1) the habeas court correctly determined that Defendant failed to demonstrate ineffective assistance of counsel; (2) Defendant's due process claim regarding cross-examination of the victim concerning her sexual activity before the rape and her post-rape drug charge were res judicata; and (3) the habeas court correctly determined that Defendant's remaining due process argument lacked evidentiary support.View "Fast Horse v. Weber" on Justia Law

Defendant and his stepson were jointly charged with thirteen felonies. Prior to trial, Defendant unsuccessfully moved to sever charges and for relief from prejudicial joinder. At trial, Defendant filed a motion for judgment of acquittal on all charges stemming from two of the burglaries, which the trial court also denied. Defendant was subsequently convicted on nine of the thirteen felonies. The Supreme Court affirmed, holding that the trial court did not err in (1) denying Defendant's motion for judgment of acquittal because the evidence was sufficient to support Defendant's convictions; and (2) denying Defendant's motion to sever charges and for relief from prejudicial joinder because the charges were properly joined and Defendant failed to show the denial of his motion to sever charges resulted in clear prejudice to his substantial rights.View "State v. Dowty" on Justia Law

Defendant pleaded guilty to grand theft by insufficient funds check. Defendant was subsequently sentenced to eight years in the penitentiary. Defendant appealed, arguing that the trial judge failed properly to advise him of all of his constitutional and statutory rights at his plea hearing and that his sentence violated the Eighth Amendment. The Supreme Court affirmed, holding (1) Defendant knowingly and voluntarily entered his guilty plea; and (2) Defendant’s contention that his eight-year penitentiary sentence constituted cruel and unusual punishment was without merit. View "State v. King" on Justia Law

The South Dakota Department of Labor and Regulation, Unemployment Insurance Division disqualified Plaintiff from unemployment insurance benefits based on Plaintiff's alleged failure, without good cause, to accept work she was capable of performing. After Plaintiff missed a telephonic hearing on her appeal, an ALJ entered an order of dismissal and denied Plaintiff's request to reopen for failure to show good cause. The circuit court affirmed, concluding that the Department did not err in refusing to reopen Plaintiff's claim. The Supreme Court affirmed dismissal, holding that Plaintiff did not provide evidence of untimely receipt of her notice of the hearing to carry her burden to show good cause, and therefore, Plaintiff received sufficient due process.View "Eiler v. Dep't of Labor & Regulation" on Justia Law

A federal court issued an arrest warrant for Christopher Yellow Eagle, whose warrant was referred to a task force that included federal and county law enforcement officers. The task force officers learned Yellow Eagle was living with Defendant, who had an outstanding warrant for her arrest. The task force arrested Defendant and Yellow Eagle at Defendant’s home after observing that Defendant and Yellow Eagle appeared to be under the influence of a controlled substance and had drugs on their persons. After a court trial, Defendant was convicted of possession of a controlled substance and sentenced to four years incarceration with four years suspended. Defendant appealed the circuit court’s denial of her motion to suppress, arguing (1) the task force officers who executed the arrest warrant were not authorized to enter her home to arrest her, and (2) because Yellow Eagle was a third party in her home, the officers were required to obtain a separate search warrant for the home. The Supreme Court affirmed, holding that the task force officers constitutionally entered Defendant’s home to arrest Defendant, or alternatively, Yellow Eagle. View "State v. Quevedo" on Justia Law

After a jury trial, Defendant was found guilty of eight counts of making false or fraudulent sales tax returns. On appeal, Defendant argued that the circuit court erred in (1) denying his Batson challenges to three peremptory strikes exercised by the State because the court’s Batson analysis was incomplete; and (2) denying his motion for judgment of acquittal. The Supreme Court (1) held that because the Court was unable to determine under the record the circuit court’s reason for denying the Batson challenges, limited remand was required to allow the circuit court to engage in the missing analysis; and (2) affirmed the denial of Defendant’s motion for judgment of acquittal, as the evidence was sufficient to sustain the convictions. View "State v. Guthmiller" on Justia Law

In 2001, Plaintiff, a Honduran national, pleaded guilty to a felony in South Dakota and received a four-year suspended sentence. In 2013, Plaintiff filed a petition for a writ of error coram nobis seeking to vacate his 2001 conviction, asserting that the conviction was invalid because he pleaded guilty without being given Padilla and Boykin advisements. The circuit court granted the State’s motion for summary judgment. The Supreme Court affirmed, holding that because coram nobis was unavailable to remedy Plaintiff’s claimed Padilla and Boykin violations, the circuit court correctly granted summary judgment in favor of the State. View "Garcia v. State" on Justia Law

Defendant pleaded guilty to several offenses, including first-degree felony murder. Defendant was sentenced to death on the murder charge. The Supreme Court affirmed Defendant’s conviction and sentence. Defendant subsequently filed an application for writ of habeas corpus, claiming that he did not validly waive his right to have a jury determine whether to impose the death penalty. The Supreme Court granted the writ and vacated Defendant’s death sentence. On remand, Defendant filed a motion to withdraw his guilty pleas. The circuit court denied the motion on the merits, and the case proceeded to a jury sentencing. Thereafter, the jury sentenced Defendant to death. The Supreme Court affirmed the denial of Defendant’s motion to withdraw his guilty pleas and the proportionality of his sentence, holding (1) although the circuit court’s denial on the merits of Defendant’s motion to withdraw his guilty pleas was in excess of what was permitted by the limited remand, Defendant’s motion to withdraw his guilty pleas was properly denied; and (2) Defendant’s sentence was lawfully imposed by the jury. View "State v. Piper" on Justia Law

Hutterville Colony, a nonprofit religious corporation, had two opposing factions. Both factions sought exclusive power over Hutterville. Their schism led to two lawsuits, including one faction's suit seeking judicial dissolution of Hutterville. Eventually, the Supreme Court ordered dismissal of the suit, concluding that the circuit court lacked subject matter jurisdiction to order judicial dissolution of Hutterville. This appeal concerned the circuit court's actions following the Court's decision. The Supreme Court affirmed, holding (1) the circuit court did not err when it continued to exercise jurisdiction over Hutterville and its property following remittitur; (2) the circuit court had the authority and duty to wind up the receivership and discharge the receiver; (3) the circuit court did not abuse its discretion in ordering payment of the receiver's fees and expenses from receivership funds and allowing the receiver to use receivership funds to pay the expenses of third parties; (4) the circuit court did err in releasing the receiver from liability, as the receiver's appointment and receivership were valid under state law; and (5) the circuit court did not err in ordering the receiver to return receivership funds to the corporation. View "Wipf v. Hutterville Hutterian Brethren" on Justia Law

After a jury trial, Defendant was convicted of manslaughter in the first degree. The Supreme Court affirmed, holding that the trial court (1) did not abuse its discretion in denying Defendant's motion to suppress and in admitting a video of Defendant's first interrogation, as Defendant made a knowing, voluntary, and intelligent waiver of her Miranda rights in the first interrogation; (2) did not err in refusing to instruct the jury on the lesser offense of manslaughter in the second degree; and (3) did not err in denying a jury instruction on burglary and allowing Defendant's counsel to appropriately argue the elements of justifiable homicide. View "State v. Waloke" on Justia Law