Justia South Dakota Supreme Court Opinion Summaries

Defendant was indicted for murder in the second degree and aggravated assault after stabbing two men during an altercation. Defendant moved to suppress statements he made during a custodial interrogation, arguing that he had not validly waived his Miranda rights and that his statements were not voluntary. The circuit court denied the motion. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that Defendant's statements were obtained pursuant to a valid Miranda waiver and that the statements were voluntarily made; and (2) there was sufficient evidence to support the jury's rejection of Defendant's claim of self-defense. View "State v. Strozier" on Justia Law

After a jury trial, Defendant was convicted of driving under the influence of alcohol and for an open container violation. Defendant appealed, arguing that the trial court incorrectly denied his motion to suppress evidence obtained after the stop of his vehicle because the law enforcement officer had no reasonable suspicion of a violation of law to support the stop. The Supreme Court affirmed the conviction, holding that the circuit court did not err in denying Defendant's motion to suppress because the officer had a reasonable suspicion that Defendant's crossing of the fog line violated a statute requiring Defendant's vehicle to be "driven as nearly as practicable entirely within a single lane." View "State v. Hett" on Justia Law

Defendant, who was born in Mexico but moved to the United States before he was one year old, pleaded guilty to possession of marijuana. The United States later commenced removal proceedings against Defendant and Defendant was deported. Defendant later re-entered the United States. Defendant filed a motion to re-open and vacate his conviction for felony possession of marijuana, arguing that his counsel was deficient and that he would not have pleaded guilty if his counsel had advised him of the potential deportation consequences. The trial court denied the motion. The Supreme Court affirmed, holding that the U.S. Supreme Court's decision in Padilla v. Kentucky does not apply retroactively to a conviction that was final at the time Padilla was decided, including Defendant's conviction. View "State v. Garcia" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree rape and two counts of sexual contact with a child under age sixteen. Defendant was sentenced to fifty years incarceration for each of the first-degree rape convictions and fifteen years for each of the sexual contact convictions, with the sentences to run concurrently. Defendant appealed, arguing, among other things, that the indictment was duplicitous, and therefore, his right to jury unanimity was violated. The Supreme Court affirmed, holding (1) the trial court did not commit plain error in failing to strictly comply with the "either or rule" by either requiring the State to specifically elect the acts it would rely on at trial or by giving a unanimity instruction because the jury was ultimately informed of the unanimity requirement; (2) sufficient evidence supported both of Defendant's sexual contact convictions, but the evidence presented at trial was only sufficient to support one of Defendant's first-degree rape convictions; and (3) the sentences imposed by the trial court did not violate Defendant's Eighth Amendment right against cruel and unusual punishment. View "State v. Brende" on Justia Law

M.E.H. alleged she was kidnapped and raped by Defendant in 2000. The charges against Defendant were dismissed when DNA testing failed to implicate him. In 2008, the case was reopened, and the evidence obtained in 2000 was retested using a new method of DNA testing, which revealed the presence of Defendant's DNA. Defendant was again indicted, and a part II information was filed charging Defendant as a habitual offender. The jury found Defendant guilty of rape in the second and third degree and related charges. In a separate trial, the jury found Defendant was a habitual offender. The Supreme Court reversed, holding that the trial court (1) did not abuse its discretion in admitting evidence of an incident involving another alleged victim as other acts evidence; (2) did not violate Defendant's right to confrontation by admitting testimony regarding the results of the DNA testing performed in 2008 and 2011, even though some steps of the testing were performed by nontestifying analysts; but (3) because the State's filing of an amended part II information effectively dismissed the original part II information, the State's dismissal of the amended part II information left the trial court without jurisdiction over the habitual offender proceedings. Remanded for resentencing. View "State v. Medicine Eagle" on Justia Law

After a jury trial, Defendant was found guilty of possession of marijuana and possession of drug paraphernalia. Defendant appealed, asserting that the jury had insufficient evidence to find that he possessed the marijuana found in the apartment he resided in. Defendant's girlfriend was listed as the apartment's only tenant. The Supreme Court affirmed, holding that the State produced sufficient evidence to sustain the conviction, as (1) Defendant had at least joint control over the dresser where the marijuana was found and thus joint control over the marijuana; and (2) Defendant's had a knowledge of the specific character and location of the marijuana. View "State v. Wheeler" on Justia Law

The State charged Defendant with bigamy in violation of S.D. Codified Laws 22-22A-1. Defendant moved to dismiss the information, arguing that the State failed to state a public offense. Specifically, Defendant argued that because a bigamous marriage is void ab initio under S.D. Codified Laws 25-1-8, he was never legally married the second time, and thus, it was legally impossible to prosecute him for bigamy. The trial court accepted this argument and dismissed the case. The Supreme Court reversed, holding that in order to give meaning and effect to the enactment of section 22-22A-1, bigamy is committed when a person enters into a purported marriage contract or relationship at a time when the person already has a living spouse. Remanded. View "State v. Clements" on Justia Law

Defendant was charged with numerous crimes, including grand theft. Defendant entered into an agreement with the State in which the State agreed to defer prosecution of the grand theft charge if Defendant pleaded guilty to other charges and complied with additional conditions, one of which required Defendant to plead guilty to grand theft if he violated any of the other conditions of the agreement. Defendant later violated some of the conditions of the agreement, and consequently, the State re-filed the grand theft charge against Defendant. Defendant filed a motion to exercise his right to a jury trial. The circuit court denied the motion based on the terms of the agreement. Defendant subsequently pleaded guilty to grand theft and was sentenced. The Supreme Court reversed, holding (1) the portion of the agreement requiring Defendant to plead guilty to grand theft was unenforceable because it unconstitutionally deprived Defendant of his right to voluntarily enter his choice of plea on the grand theft charge; and (2) because that portion of the agreement was unenforceable, the circuit court erred in determining that Defendant was bound by that portion of the agreement and in subsequently denying Defendant's motion to exercise his right to a jury trial. View "State v. Fox" on Justia Law

A law enforcement officer stopped a vehicle driven by Shane Erwin for making an illegal left turn. After engaging in routine traffic stop questioning, the officer became suspicious and walked his drug-sensing dog around Defendant's vehicle. Drugs and drug paraphernalia were later found in the vehicle. Shane and his father, Richard Erwin, who was traveling in the vehicle, were both arrested. The Erwins moved to suppress evidence, alleging an illegal stop. The trial court granted the motion. The Supreme Court reversed, holding that the officer had probable cause to stop the Erwins because he witnessed a violation of S.D. Codified Laws 32-26-18, which requires that a left turning vehicle turn into the left most lawfully available lane. Remanded. View "State v. Erwin" on Justia Law

After a jury trial, Defendant was convicted of sexual contact with a child under the age of sixteen. Defendant appealed, arguing that his arraignment was inadequate and that the trial court erred in denying his motion for a new trial. The Supreme Court affirmed, holding (1) because Defendant had sufficient notice of the charge against him, pleaded not guilty, exercised his rights, and had an adequate opportunity to defend himself at trial, there was no error in the arraignment; and (2) Defendant waived his argument that the trial court erred in failing to enter a specific finding that the minor victim was a competent witness, and therefore, the trial court did not err in denying Defendant's motion for a new trial. View "State v. Anderson" on Justia Law