Justia South Dakota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of second-degree rape. Defendant appealed a number of issues involving hearsay and the denial of a requested jury instruction, a Batson challenge, and an objection regarding the State's use of the word "rape" during trial. The Supreme Court affirmed, holding (1) Defendant's challenges to testimony admitted at trial were either not preserved for appeal or were without merit; (2) the instructions that were given to the jury accurately stated the law and were not prejudicial to Defendant; (3) the trial court correctly denied Defendant's Batson challenge to the State's peremptory strike of a juror; and (4) the trial court did not abuse its discretion in denying Defendant's objection to the use of the word "rape" during trial. View "State v. Roach" on Justia Law

Defendant was charged separately with DUI and distribution of a controlled substance. A plea agreement was reached in both cases. The state's attorney's office agreed to recommend that the DUI sentence run concurrent to the sentence imposed for the distribution charge. At Defendant's sentencing hearing, the attorney general's office initially argued against running the sentences concurrently. The assistant attorney general, however, when made aware of the plea agreement, withdrew his argument against concurrent sentences. The circuit court sentenced Defendant to six years for the DUI and five years for the distribution charge, the sentences to be served consecutively. Defendant appealed, arguing that the State breached the plea agreement by initially arguing against concurrent sentences. The Supreme Court affirmed the sentences because Defendant did not contemporaneously object to the alleged violation of the plea agreement and because Defendant did not establish that the error caused him prejudice. View "State v. Olvera" on Justia Law

Defendant was charged with and found guilty of aggravated child abuse. The charges stemmed from the bruising found on the face of Defendant's fiancee's daughter, six-year-old K.N., while K.N. was at school. Defendant appealed, arguing that the verdict was not sustained by the evidence. The Supreme Court affirmed the conviction, holding that there was sufficient evidence to support Defendant's conviction beyond a reasonable doubt, as evidence was presented from which the jury could find that Defendant's grabbing and squeezing of K.N.'s face were enough to cause extensive bruising across K.N.'s face and neck and a subconjunctival hemorrhage in one of her eyes, and that Defendant's actions were not permissible discipline. View "State v. Morgan" on Justia Law

Defendant was convicted of arson in connection with a fire in her apartment. Defendant appealed, arguing that the circuit court abused its discretion in denying her motions for judgment of acquittal and new trial based on a claim of ineffective assistance of trial counsel and by excluding an out-of-court statement made by her estranged sister. The Supreme Court affirmed, holding (1) because the existing court record did not establish a manifest usurpation of Defendant's constitutional rights, her ineffective assistance of counsel claim was not ripe for review; and (2) the out-of-court statement was inadmissible hearsay, and therefore, the district court did not abuse its discretion in excluding the statement. View "State v. Hannemann" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty but mentally ill to ten counts of grand theft. Defendant filed a motion to withdraw her guilty but mentally ill pleas prior to sentencing. The circuit court denied the motion. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in denying Defendant's motion to withdraw her pleas of guilty but mentally ill; (2) Defendant's due process rights were not violated when she was denied the opportunity to review and comment on the entire presentence investigation report prior to sentencing; (3) Defendant's claim that she was denied the effective assistance of counsel was not ripe for review on direct appeal; and (4) Defendant's sentence was not cruel and unusual punishment under the Eighth Amendment. View "State v. Schmidt" on Justia Law

Following a jury trial, Defendant was convicted of malicious intimidation or harassment, first-degree burglary, disorderly conduct, and commission of a felony while armed with a firearm for an incident in which Defendant and Robert Anderson entered the home of Summer Neuman and caused a ruckus. The Supreme Court reversed, holding (1) the trial court did not err in denying Defendant's motion for judgment of acquittal on his conviction of commission of a felony while armed with a firearm; but (2) the trial court committed a prejudicial error by precluding Defendant from introducing evidence regarding Anderson's suspicion that individuals residing in Neuman's house had stolen tires from Anderson and committed other thefts, as the court's ruling excluded relevant evidence of Defendant and Anderson's intent. View "State v. Jucht" on Justia Law

Dennis Most was convicted in a bench trial of four counts of sexual contact with a child. Most appealed, contending (1) the trial court erred in denying his motion to exclude prior acts evidence and his motion to offer the victim's prior allegation of sexual assault, and (2) there was insufficient evidence to sustain his convictions. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion when it admitted prior acts evidence; (2) the trial court did not abuse its discretion when it denied Most's motion to offer evidence of the victim's prior allegation of sexual assault; and (3) there was sufficient evidence to sustain Most's convictions. View "State v. Most" on Justia Law

Kyle Steiner pleaded guilty to one count of sexual contact with a child and was sentenced to fifteen years in prison. Steiner subsequently filed an application for a writ of habeas corpus, claiming that his trial counsel was ineffective. Without conducting an evidentiary hearing, the circuit court dismissed the application. The Supreme Court reversed the judgment of the circuit court, holding that the circuit court was premature in dismissing Steiner's petition without conducting an evidentiary hearing on the merits, as Steiner alleged facts which, if proven to be true, would support a claim for relief, and Steiner's allegations were not unspecific, conclusory, or speculative. View "Steiner v. Weber" on Justia Law

A jury found Trent Danielson guilty of perjury. Danielson appealed, arguing that the evidence was insufficient to sustain the verdict, the trial court erred in denying his motion for a court-appointed private investigator, and the court erred in denying a motion in limine and admitting used transmission parts into evidence. The Supreme Court affirmed, holding (1) there was sufficient evidence to sustain the jury's guilty verdict, as a rational trier of fact could have found the essential elements of perjury beyond a reasonable doubt; and (2) the trial court did not abuse its discretion in denying Danielson's motion for appointment of a private investigator, motion in limine to exclude the transmission parts, and motion to dismiss for the destruction of evidence. View "State v. Danielson" on Justia Law

Appellant Ryan Rademaker was arrested for driving while under the influence of alcohol. Rademaker moved to suppress all evidence obtained from the stop of his vehicle, arguing that the stop violated his Fourth Amendment right to be free from unreasonable search and seizures. The trial court denied his motion and convicted Rademaker of driving under the influence. Rademaker appealed. The Supreme Court affirmed the trial court's ruling on the issue, holding that, based on the totality of the circumstances, the law enforcement officer had reasonable suspicion to stop Rademaker's car, and thus, the stop did not violate Rademaker's Fourth Amendment rights. View "State v. Rademaker" on Justia Law