Justia South Dakota Supreme Court Opinion Summaries

Appellant pleaded guilty to committing manslaughter in the first degree and was sentenced to an eighty-five-year term of imprisonment. Appellant did not directly appeal his sentence or the sentencing court’s acceptance of his guilty plea. Appellant later filed an amended application of writ of habeas corpus, alleging that he received ineffective assistance of counsel because defense counsel decided to forgo a motion to suppress statements Appellant made to law enforcement officers and because defense counsel failed properly to advise Appellant on his right to appeal the sentencing court’s decision. The circuit court denied the petition. The Supreme Court affirmed, holding (1) defense counsel had sound legal reasons for the decision not to move to suppress the incriminating statements; and (2) Appellant was not prejudiced by missing the opportunity to appeal his sentence or the circuit court’s acceptance of his guilty plea. View "McDonough v. Weber" on Justia Law

The Morris Family LLC (Morris Family) owns certain property abutting U.S. Highway 212 in the City of Watertown. In a 1970 condemnation action against Morris Family’s predecessor in title, the State sought to acquire the necessary “right of way and rights of access” in accordance with its plan to turn Highway 212 into a four-lane, controlled-access highway. The parties to the condemnation action eventually settled. In 2010, Morris Family filed a complaint against the City and State, claiming unconstitutional taking or damaging of property for the loss of access from their property to Highway 212 and violation of due process stemming from the State’s and City’s denial of access. The circuit court granted summary judgment for the State, concluding that the State was granted complete control of access for the land in the 1970 judgment. The Supreme Court affirmed, holding that the motion for summary judgment was properly before the circuit court and that the court did not err when it granted summary judgment on all claims and dismissed the case. View "Morris Family LLC v. S.D. Dep’t of Transp." on Justia Law

Defendant was stopped after a highway patrol trooper registered Defendant’s car traveling at 112 miles per hour. Defendant, who was under the influence of alcohol and marijuana, was traveling with three small children in the vehicle. After a trial, Defendant was found guilty of abuse of a minor in violation of S.D. Codified Laws 26-10-1 because he had “exposed” the children as stated by the statute. Defendant appealed, asserting that section 26-10-1 is unconstitutionally vague because the statute does not define the word “expose.” The Supreme Court affirmed, holding that, even though section 26-10-1 does not include a definition of the word “expose,” the statute is not unconstitutionally vague because it affords the public adequate notice as to the conduct proscribed and does not allow law enforcement unfettered discretion to enforce it. View "State v. Myers" on Justia Law

In 2013, Defendant was arrested for driving under the influence (DUI). The State filed a part II information charging Defendant with third offense DUI based on a 2005 DUI conviction and a 2012 DUI conviction. Defendant challenged the validity of his 2005 DUI conviction for sentence-enhancement purposes, arguing that the conviction was constitutionally invalid because he did not knowingly and voluntarily enter his guilty plea. The circuit court found that the plea was involuntary under the factual circumstances and struck the 2005 DUI conviction from the part II information. The Supreme Court reversed, holding that, based on the Court’s recent decision in State v. Chant, Defendant may not collaterally attack his 2005 conviction for sentence-enhancement purposes because he waived his right to counsel in the 2005 proceedings. View "State v. Wolf" on Justia Law

In August 2011, an indictment issued charging Defendant with one count of aggravated child abuse between March 24, 2011 and March 28, 2011. Defense counsel requested that the jury be instructed that they must determine guilt or innocence on each incident, the one on March 24 and the one on March 28. The court refused the requested jury instruction. The jury subsequently returned a verdict of guilty on the single count of aggravated child abuse. Defendant appealed, arguing that he was denied the right to a unanimous jury verdict because there was no way to determine whether all twelve jurors agreed upon the commission of the same act in order to commit him of the charged offense. The Supreme Court reversed, holding (1) the State presented two incidents of trauma, each of which could have formed the basis of aggravated child abuse, and the instructions only informed the jury that the verdict must be unanimous; and (2) therefore, the circuit court erred by not providing the jury with a special unanimity instruction requiring it to agree on the act supporting the conviction or to find that Defendant had committed both acts of child abuse. Remanded for a new trial. View "State v. White Face" on Justia Law

In 1996, Defendant, who was sixteen years old at the time, pleaded guilty and was sentenced to a term of thirty-three years in prison for kidnapping. In 2012, Defendant filed a pro se motion to correct an illegal sentence, arguing that his sentence was unconstitutional based on the United States Supreme Court decisions Roper v. Simmons, Graham v. Florida, and Miller v. Alabama. The circuit court denied the motion. The Supreme Court affirmed, holding that Defendant did not receive life without parole or a de facto life sentence because he had the opportunity for release at age forty-nine, and therefore, Defendant was unable to establish that Roper, Graham, and Miller applied to him. View "State v. Springer" on Justia Law

Appellant pleaded guilty to possession of a controlled drug or substance. The circuit court sentenced Appellant to five years in prison with two years suspended and fined him $10,000. The two suspended years of imprisonment were conditioned on Appellant paying the fine. On appeal, Appellant argued that the $10,000 fine for possession of a controlled drug or substance was grossly disproportionate to the offense in violation of the Eighth Amendment prohibition on excessive fines. The Supreme Court affirmed, holding that Appellant failed to make a prima facie showing that the $10,000 fine was grossly disproportionate to the offense. View "State v. Webb" on Justia Law

After a jury trial, Defendant was convicted of rape and two counts of aggravated assault and sentenced to ten years in prison on each count, to be served concurrently. The Supreme Court affirmed, holding (1) the circuit court did not commit structural error by allowing the State’s reasonable doubt standard to be presented to the jurors during voir dire; (2) the State’s questioning during voir dire amounted to plain error, but Defendant’s substantial rights were not impacted by the prosecutor’s improper comments; and (3) the evidence was sufficient to support Defendant’s convictions, and therefore, the circuit court did not err in denying Defendant’s motion for judgment of acquittal. View "State v. Hayes" on Justia Law

Petitioner pleaded guilty to manslaughter in the first degree. Petitioner subsequently filed a motion to withdraw his guilty plea, which the circuit court denied. The Supreme Court affirmed the denial. Thereafter, Petitioner filed an amended and second amended application for a writ of habeas corpus, claiming that his due process rights were violated and that he was denied the right to effective assistance of counsel. The habeas court denied relief. The Supreme Court affirmed, holding (1) Petitioner’s guilty plea was voluntary and intelligent; (2) the circuit court did not abuse its discretion when it denied Petitioner’s motion to withdraw his guilty plea; and (3) Petitioner was not denied effective assistance of counsel. View "LeGrand v. Weber" on Justia Law

Defendant was convicted of first-degree arson and first-degree felony murder for intentionally setting fire to an occupied structure, resulting in the death of an unidentified victim in the fire. Defendant was sentenced to concurrent life sentences without parole for each conviction. Defendant filed a motion to correct an illegal sentence, claiming that the concurrent sentences violated the constitutional prohibition against double jeopardy. The circuit court denied Defendant’s motion. The Supreme Court affirmed, holding that the Legislature intended to authorize cumulative punishment for violations of felony murder and the underlying felony of arson, and therefore, the circuit court was authorized by the Legislature to impose concurrent sentences for both crimes. View "State v. Garza" on Justia Law