Justia South Dakota Supreme Court Opinion Summaries

Defendant pleaded guilty to first-degree burglary. The circuit court sentenced Defendant to twenty years in prison with four years suspended and credit for time served. Defendant appealed, alleging that he received ineffective assistance of counsel, that the circuit court erred in denying his request for a new trial, and that his sentence constituted cruel and unusual punishment. The Supreme Court reversed, holding that the circuit court erred when it did not address Defendant’s motion for a change of counsel. Remanded for the circuit court to appoint new counsel and conduct a new sentencing hearing. View "State v. Martinez" on Justia Law

A jury convicted Cleve Janis, Jr. of third-degree rape in 2015. Janis appealed, arguing that the circuit court erred when it admitted undisclosed expert testimony. Janis also argued that the prosecutor committed misconduct through various statements during trial and that there was improper contact between a juror and a spectator. Finding no reversible error, the Supreme Court affirmed. View "South Dakota v. Janis" on Justia Law

Appellant pleaded guilty to simple assault. Appellant was sentenced to two years in the penitentiary - the maximum penalty - with no credit for time served. Appellant appealed, challenging the circuit court’s failure to give credit for time served and the constitutionality of his sentence. The Supreme Court affirmed, holding (1) the circuit court erred in failing to give credit for time served; and (2) Appellant’s sentence was not grossly disproportionate to the crime of simple assault and was thus constitutional under the Eighth Amendment. Remanded for correction of Appellant’s sentence to give credit for time served. View "State v. Ainsworth" on Justia Law

After a jury trial, Defendant was convicted of simple assault. Defendant appealed, arguing that the prosecutor’s reference to Defendant’s attorney in cross-examination and closing argument violated his Sixth Amendment right to counsel and deprived him of a fair trial. The Supreme Court affirmed Defendant’s convictions, holding (1) under the circumstances of this case, the prosecutor’s statements improperly suggested to the jury that Defendant and his defense counsel concocted a false defense to avoid a guilty verdict; but (2) a new trial was not warranted because Defendant was not prejudiced. View "State v. Pursley" on Justia Law

Appellant pleaded guilty to aggravated assault against a law enforcement officer. Appellant was sentenced to twenty-two years in prison. Appellant later filed a petition for writ of habeas corpus, arguing that his trial counsel provided constitutionally ineffective assistance and that his sentence was cruel and unusual punishment under the Eighth Amendment. After a hearing, the circuit court denied habeas relief. The Supreme Court affirmed, holding (1) Appellant did not receive ineffective assistance of counsel regarding his right to appeal and his right to remain silent during the presentence investigation; and (2) Appellant’s sentence was not unconstitutionally cruel or unusual. View "Stark v. Weber" on Justia Law

After a jury trial, Defendant was found guilty of second-degree murder and aggravated assault. The Supreme Court affirmed, holding (1) the trial court’s decision to instruct the jury on second-degree murder did not deprive Defendant of his constitutional right to notice of the charges against him and his right to defend against such charges where second-degree murder was not charged in the indictment; (2) the circuit court did not deny Defendant his right to confront witnesses by limiting his cross-examination of a State witness; (3) the circuit court did not err in refusing to suppress Defendant’s statements made to an officer immediately after the shooting; and (4) Defendant’s sentence for aggravated assault was not cruel and unusual in violation of the Eighth Amendment. View "State v. McCahren" on Justia Law

Appellant pleaded guilty to first-degree murder. Appellant was sentenced to eighty years’ imprisonment and ordered to reimburse the county for costs of prosecution. Appellant later filed a petition for writ of habeas corpus, raising six issues for review. The circuit court denied the claims after an evidentiary trial. Appellant appealed, raising three issues for review. The Supreme Court affirmed, holding (1) Appellant failed to prove that his trial counsel’s performance was deficient or that Appellant was prejudiced; (2) the State did not violate the terms of the plea-bargain agreement; and (3) the sentencing court did not err by failing to advise Appellant of his Boykin rights during sentencing. View "Keinsasser v. Weber" on Justia Law

Defendant pleaded guilty to first-degree manslaughter and was sentenced to eighty years’ imprisonment with twenty years suspended. Defendant appealed, arguing that his sentence violates the Eighth Amendment’s prohibition against cruel and unusual punishment. Specifically, Defendant argued that his sentence was cruel and unusual because it was disproportionate to the sentence that his codefendant received for the same offense. The Supreme Court affirmed, holding (1) the harshness of Defendant’s sentence is not grossly disproportionate to the gravity of his offense, and although his sentence is more severe than his codefendant’s, his culpability is correspondingly greater; and (2) therefore, the circuit court did not violate the Eighth Amendment or abuse its discretion in sentencing Defendant. View "State v. Rice" on Justia Law

After a jury trial, Defendant was convicted of fourth-degree rape. The Supreme Court affirmed on appeal, holding (1) because the record was insufficient to allow for an appropriate review of Defendant’s argument that his trial counsel provided ineffective assistance because she did not understand S.D. Codified Laws 19-19-412; (2) the circuit court did not commit prejudicial error when it concluded that Defendant was not entitled to a hearing under section 19-19-412 because he did not file a motion for a hearing fourteen days before trial; (3) the circuit court did not abuse its discretion when it limited Defendant’s cross-examination of the victim to questions related to the victim’s sexual encounters with Defendant; and (4) the circuit court did not err when it considered Defendant’s juvenile psychological records to determine an appropriate sentence. View "State v. Golliher-Weyer" on Justia Law

Defendant was convicted of vehicular homicide, driving with alcohol in his blood or while under the influence of alcohol or drugs, possession of marijuana, and ingesting a non-alcoholic substance to become intoxicated. Defendant appealed, arguing that the trial court erred when in denying his motion to suppress a blood draw because law enforcement and hospital personnel took blood samples from him in violation of his constitutional rights. The Supreme Court affirmed, holding (1) blood drawn by hospital personnel for medical purposes is not subject to Fourth Amendment protection, and therefore, suppression of the draw was not warranted; and (2) exigent circumstances existed in regard to the warrantless blood draw ordered by law enforcement such that the blood draw was objectively reasonable. View "State v. Fischer" on Justia Law