Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of two counts of first-degree rape and two counts of sexual contact with a child under the age of sixteen, holding that Defendant was not entitled to relief on his claims of error.After a jury trial, Defendant was found guilty of rape and sexual contact with a minor and sentenced to two consecutive sixty-year terms of imprisonment on the rape convictions. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Defendant's motion for judgment of acquittal on the two rape charges; (2) the submission of the sexual contact charges to the jury did not violate the prohibition against double jeopardy; (3) there was no improper bolstering of witnesses at trial by either the circuit court or the prosecution; (4) the circuit court did not abuse its discretion by denying Defendant's motion for a new trial; (5) Defendant's sentence neither violated the constitutional prohibition against cruel and unusual punishment, nor did it constitute an abuse of discretion; and (6) no other prejudicial error occurred. View "State v. Manning" on Justia Law

The Supreme Court affirmed Defendant's conviction of open container and driving under the influence (DUI) and imposing a suspended imposition of sentence, holding that the circuit court did not err in denying Defendant's motion to suppress.Based on information obtained during a 911 call made by Defendant's daughter reporting that Defendant may be drinking and driving and providing Defendant's location officers conducted a traffic stop of Defendant's van and then arrested her for DUI. Defendant filed a motion to suppress, arguing that the traffic stop was an unconstitutional search and seizure. The circuit court denied the motion and found Defendant guilty. The Supreme Court affirmed, holding that, under the totality of the circumstances, the circuit court properly concluded that law enforcement had reasonable suspicion to believe that Defendant was driving under the influence of alcohol at the time of the stop. View "State v. Rosa" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for habeas corpus, holding that the circuit court did not err in denying the petition after holding an evidentiary hearing.Appellant was convicted of three counts of first-degree rape and one count of sexual contact with a child under sixteen for raping and having sexual contact with his four-year-old autistic daughter. The conviction was affirmed on appeal. Appellant later filed a petition for habeas corpus alleging several instances of ineffective assistance of counsel. After a hearing, the circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to establish that his trial counsel provided ineffective assistance. View "Spaniol v. Young" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree arson stemming from a fire that occurred in Defendant's home, for which she submitted a claim to her insurer seeking to recover for the damage to her home, holding that Defendant was not entitled to relief on her claims of error.On appeal, Defendant argued that the circuit court erred in denying her motion for judgment of acquittal and that she was denied her fundamental right to due process. The Supreme Court affirmed, holding (1) the circuit court's factual findings were legally sufficient to support a conviction of second-degree arson; (2) the circuit court did not err when it denied Defendant's motion for judgment of acquittal; and (3) Defendant was not denied her constitutional right to due process and a fair trial. View "State v. Krouse" on Justia Law

The Supreme Court affirmed the judgment of the habeas court denying Appellant's amended application for a writ of habeas corpus alleging that the indictment under which he was charged did not describe a public offense and that he was convicted and sentenced in violation of constitutional provisions prohibiting an ex post facto application of a criminal statute, holding that there was no error.Appellant pled nolo contendere to first-degree rape of a child under thirteen years of age and sexual contact without consent against his daughter. The habeas court denied the habeas application, concluding that Appellant's claim was non-jurisdictional and thus waived when he pled nolo contendere pursuant to a plea agreement with the State. The Supreme Court affirmed, holding that Appellant failed to assert a claim upon which his judgment could be void. View "Lacroix v. Fluke" on Justia Law

The Supreme Court reversed the decision of the circuit court finding co-defendants Adrianna Reecy and Kevin Dickerson guilty of robbery and burglary and also finding Dickerson guilty of aggravated assault against Julio Rojas, holding that exclusion of certain evidence resulted in violation of both defendants' Sixth Amendment right of confrontation.On appeal, both defendants argued that the circuit court erred in precluding any reference to Rojas's immigration status and in admitting into evidence an exhibit listing transactions from Rojas's debit card. The Supreme Court agreed and reversed, holding (1) the circuit court's exclusion of the immigration evidence was error, and the error was not harmless; and (2) the circuit court erred in admitting the bank records at issue because the State did not lay an adequate foundation for the admission of the documents and the court erroneously determined that Rojas was a qualified witness, as contemplated by the exception to the hearsay rule. View "State v. Dickerson" on Justia Law

The Supreme Court affirmed Defendant's sentence imposed in connection with his plea of guilty to attempted first-degree murder and commission of a felony with a firearm, holding that the sentence did not violate the Eighth Amendment, nor was it an abuse of the circuit court's sentencing discretion.Defendant and the State entered into a plea agreement under which Defendant agreed to plead guilty to attempted first-degree murder and commission of a felony with a firearm. After a sentencing hearing, the circuit court sentenced Defendant to a total of thirty years in prison. The Supreme Court affirmed, holding that the circuit court (1) did not abuse its discretion in imposing the sentence, and (2) Defendant failed to demonstrate that his sentence transgressed the Eighth Amendment's prohibition against cruel and unusual punishment. View "State v. Deleon" on Justia Law

The Supreme Court affirmed Defendant's conviction of burglary and two counts of simple assault arising from a home invasion, holding that Defendant was not entitled to relief on his allegations of error.After a jury trial, Defendant was convicted of burglary and simple assault. Defendant was tried on a part two habitual offender information alleging two prior felon convictions. The jury found Defendant to be a habitual offender. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Defendant's motion to suppress the show-up identification; (2) did not err in denying Defendant's motion for a mistrial; and (3) did not err in denying Defendant's motion for judgment of acquittal in the habitual offender trial. View "State v. Red Cloud" on Justia Law

The Supreme Court affirmed the magistrate court's decision granting Defendant's motion to suppress, holding that the magistrate court did not err in determining that the community caretaker exception to the Fourth Amendment did not apply.After Sioux Falls dispatch received a call from a six-year-old boy saying that "daddy was being mean to mom" and that his dad was leaving to go to his car an officer followed the dad (Defendant) in his automobile. The officer initiated a traffic stop and, after further investigation, placed Defendant under arrest for driving under the influence and driving with a suspended license. Defendant filed a motion to suppress, arguing that the officer stopped his car without probable cause or a reasonable and articulable suspicion. The magistrate court granted the motion to suppress. The Supreme Court affirmed, holding that the officer's actions were beyond the scope of a community caretaker, and therefore, Defendant's motion to suppress was properly granted. View "State v. Grassrope" on Justia Law

The Supreme Court affirmed the judgment of the habeas court dismissing Defendant's application for habeas corpus, holding that the court did not err.A jury convicted Defendant of fourteen sex offenses. On appeal, Defendant argued that his due process right to jury unanimity was denied and that the prosecutor's remarks during opening statement denied him a fair trial. The Supreme Court affirmed. Defendant later filed an application for writ of habeas corpus alleging ineffective assistance of counsel based on the errors he alleged on appeal. The habeas court dismissed the application. The Supreme Court affirmed, holding (1) Defendant was precluded from demonstrating prejudice for Strickland purposes in a subsequent habeas corpus proceeding; and (2) the habeas court properly dismissed Defendant's amended application for a writ of habeas corpus on summary judgment. View "Neels v. Dooley" on Justia Law