Justia South Dakota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of one count of second-degree burglary and four counts of identity theft. Defendant subsequently pleaded guilty but mentally ill to grand theft. Defendant appealed, challenging both his jury convictions and the sentences imposed for each of his crimes. The Supreme Court affirmed, holding (1) the performance of defense counsel did not clearly deprive Defendant of his constitutional rights to counsel and a fair trial; (2) Defendant’s sentence did not violate the Eighth Amendment’s prohibition against cruel and unusual punishment; and (3) the circuit court did not err by denying Defendant’s motion for judgment of acquittal on the charges of second-degree burglary and identity theft. View "State v. Chipps" on Justia Law

After a jury trial, Defendant was convicted of possession of methamphetamine, possession of two ounces or less of marijuana, and possession of drug paraphernalia. The Supreme Court affirmed, holding (1) the circuit court did not err when it denied Defendant’s motion to suppress evidence of methamphetamine presented to the jury, as (i) Defendant did not preserve his arguments regarding the validity of his arrest and the subsequent search of his person, and (ii) the search of Defendant’s vehicle was constitutional; and (2) the jury was presented with sufficient evidence to conclude beyond a reasonable doubt that Defendant knowingly possessed methamphetamine. View "State v. Fischer" on Justia Law

In 2014, the Supreme Court vacated Defendant’s conviction of aggravated theft by deception, holding that the State failed to prove all the elements of the offense. The State subsequently brought new charges against Defendant for forgery and offering false or forged instruments for filing, registering, or recording in a public office. Defendant moved to dismiss the charges, asserting that double jeopardy, collateral estoppel, and res judicata barred the State’s subsequent prosecution because the State had a full and fair opportunity to litigate the newly-indicted charges during the first trial. Defendant further asserted that the indictment should be dismissed for improper venue. The circuit court denied the motion to dismiss, and a jury subsequently found Defendant guilty of all charges. The Supreme Court affirmed, holding (1) because the newly-indicted charges were separate and distinct from the charges dismissed in the first trial, the State was not precluded from retrying Defendant under double jeopardy and res judicata principles; and (2) there was sufficient evidence for the jury to have concluded that venue was proper on all charges. View "State v. Thomason" on Justia Law

Defendant was searched pursuant to a search warrant with an “all persons” provision. Defendant was found in possession of marijuana and methamphetamine. Defendant was subsequently convicted of possession of a controlled substance and possession of marijuana. Prior to trial, Defendant moved to suppress evidence obtained a result of the search, arguing that the affidavit in support of the search warrant lacked probable cause for the “all persons” provision. The circuit court denied the motion, concluding that the affidavit adequately established probable cause for issuance of a warrant with the “all persons” provision. The Supreme Court affirmed, holding that the officers’ good-faith reliance on the warrant, specifically its “all persons” provision, was objectively reasonable, thereby making suppression an inappropriate remedy. View "State v. Running Shield" on Justia Law

Defendant pleaded guilty to first-degree rape and was sentenced to seventy years’ imprisonment. Defendant did not appeal his conviction or sentence. Approximately five years later, Defendant filed a petition for habeas relief arguing, among other things, that his guilty plea was unconstitutional because the sentencing court did not properly advise him of his right against self-incrimination or that a guilty plea would waive that right. The habeas court denied relief, finding that Defendant was properly advised of his constitutional rights. The Supreme Court affirmed, holding that the habeas court did not err in concluding that Defendant failed to establish by a preponderance of the evidence that he did not knowingly and voluntarily enter his plea. View "Oleson v. Young" on Justia Law

Defendant and several others in a group were stopped by South Dakota State University (SDSU) police officers on suspicion of underage consumption and for violating South Dakota’s open container law. Defendant was later convicted of driving under the influence. Defendant appealed, arguing that the circuit court erred in denying her motion to suppress evidence stemming from the stop because law enforcement lacked reasonable suspicion and probable cause to make the stop. The Supreme Court affirmed, holding that, upon consideration of the totality of the circumstances, the SDSU police officers had an individualized, objective, and reasonable basis to believe that Defendant was engaged in criminal activity, and therefore, Defendant’s Fourth Amendment rights were not violated by the stop. View "State v. Meyer" on Justia Law

Defendant pleaded guilty to distribution of a schedule I or II substance and possession of a controlled substance. On the possession charge, the circuit court departed from presumptive probation and imposed a sentence of four years in the penitentiary, with two years suspended. Defendant appealed, arguing that her sentence for a term of imprisonment violated her constitutional right to a jury trial because the court departed from presumptive probation based on facts that were neither found by a jury nor submitted by Defendant. The Supreme Court affirmed, holding that the sentencing court appropriately sentenced Defendant. View "State v. Anderson" on Justia Law

After a jury trial, Defendant was found guilty of first-degree rape and sexual contact with a child under the age of sixteen. The Supreme Court affirmed, holding that the circuit court did not err (1) when it denied Defendant’s motion to suppress statements that Defendant claimed were given in violation of Miranda, as Defendant was not in custody for the purposes of Miranda at the time he gave the statements; and (2) when it denied Defendant’s motion for judgment of acquittal, as there was sufficient evidence to support the convictions. View "State v. Deal" on Justia Law

Defendant was twenty-six years old when she was involved in a high-speed pursuit that resulted in life-threatening injuries for a highway patrolman. Defendant pleaded guilty to driving under the influence (DUI) and aggravated assault against a law enforcement officer. Defendant admitted to the part II informations filed for both offenses. Defendant received an aggregate sentence of 42.5 years. Defendant appealed, arguing that her sentence was grossly disproportionate to her crime in violation of the Eighth Amendment. The Supreme Court affirmed, holding that the circumstances of this case failed to suggest gross disproportionality. View "State v. Coleman" on Justia Law

Defendant pleaded guilty to one count of attempted first-degree murder and was sentenced to the maximum term of twenty-five years imprisonment. The Supreme Court affirmed, holding (1) Defendant’s sentence, which was not grossly disproportionate to Defendant’s crime, fell within the constitutional prescriptions of the Eighth Amendment; (2) the inclusion of the federal presentence investigation report in the state presentence investigation report did not violate Defendant’s due process rights; and (3) Defendant was not improperly denied counsel during his interview with court services, as Defendant did not have a Sixth Amendment right to have counsel present at the interview. View "State v. Garreau" on Justia Law