Justia South Dakota Supreme Court Opinion Summaries

The defendant was convicted after a jury trial of aggravated eluding, reckless driving, driving under suspension, and failing to stop at a stop sign, all arising from an incident in Sioux Falls, South Dakota. Law enforcement responded to a call about a family dispute, with the caller reporting that the defendant was driving a red Toyota Camry. Officers observed the vehicle and identified the defendant as the driver, who then fled at high speed through residential neighborhoods. The defendant later testified that he was not involved, did not own or drive the Camry, and denied fleeing from police.The Circuit Court of the Second Judicial Circuit, Minnehaha County, presided over the trial. Prior to trial, the defendant moved to exclude statements related to the BOLO alert and the caller’s association of him with the Camry, arguing hearsay and character evidence grounds. The court denied these motions, reasoning that the BOLO and information about the vehicle were relevant to the officers’ actions and not unduly prejudicial. During trial, officers testified about the BOLO and caller’s statements, and defense counsel made a continuing objection referencing Crawford v. Washington. The jury returned guilty verdicts on all counts, and the defendant was sentenced with all terms suspended.The Supreme Court of the State of South Dakota reviewed the case. The defendant argued that admitting the caller’s statement violated his Sixth Amendment right to confrontation and constituted inadmissible hearsay. The court held that the defendant had not properly preserved the Confrontation Clause issue for appeal, as he failed to provide sufficient facts or request a determination about whether the caller’s statement was testimonial. Regarding hearsay, the court found that, even if error occurred, it was not prejudicial because the officers’ identification testimony and dash camera videos provided strong, independent evidence of the defendant’s identity. The Supreme Court affirmed the conviction. View "State v. Clifford" on Justia Law

An individual was convicted by a jury in Charles Mix County, South Dakota, for failing to appear at a pretrial conference in a pending felony case. In a separate incident, he pleaded guilty to simple assault following an altercation with another inmate at the county jail. He appealed both convictions, raising jurisdictional arguments based on his status as an enrolled member of the Yankton Sioux Tribe. He contended that both the courthouse and the jail are located in Indian country, thus depriving the state court of jurisdiction. He also challenged the denial of his motion to dismiss under the 180-day rule, the admission of certain evidence, and the denial of his motion for judgment of acquittal in the failure to appear case.The First Judicial Circuit Court denied his motions to dismiss, finding that neither the courthouse nor the jail was located in Indian country as defined by federal law. The court attributed most of the pretrial delay to the defendant’s own actions, such as refusing to participate in proceedings and to communicate with counsel, and determined the 180-day period for trial had not expired. The court also admitted evidence over his objections, including a bond form and testimony by his prior attorney, and allowed a jury to decide the failure to appear charge.The Supreme Court of the State of South Dakota reviewed both appeals together. It held that the land in question does not qualify as Indian country under 18 U.S.C. § 1151(a)-(c), reaffirming precedent that previously allotted lands that have passed into non-Indian ownership are not Indian country. The court declined to overrule its earlier decision in Bruguier v. Class. It further held that the 180-day rule was not violated, the challenged evidence was properly admitted, and sufficient evidence supported the jury’s verdict. The Supreme Court of South Dakota affirmed both convictions. View "State v. Winckler" on Justia Law

The defendant was involved in a series of criminal incidents beginning in late December 2023, including an alleged domestic assault, multiple vehicle thefts, assaulting a law enforcement officer with a vehicle, fleeing police, violating no-contact orders, drug possession, and failing to appear in court. These incidents led to six separate felony cases in Lawrence and Meade Counties. In each case, the defendant entered into plea agreements, resulting in guilty pleas to several counts in exchange for the dismissal of other charges and enhancements. The sentences imposed by the circuit court were largely concurrent, except for a consecutive sentence in the Meade County case.Following his convictions and sentencing, the defendant appealed, asserting that his guilty plea in the primary Lawrence County case was not knowing and voluntary. He claimed that both his counsel and the presentence investigation report (PSI) led him to believe he would be eligible for parole after serving a portion of his sentence, when in fact, state law rendered him ineligible for parole on the aggravated assault against a law enforcement officer charge. He further argued that, if his plea was invalid, the sentences in his other Lawrence County cases should also be vacated under the sentencing package doctrine.The Supreme Court of the State of South Dakota reviewed the totality of the circumstances and found that the plea was knowing and voluntary. The court held that neither the circuit court nor counsel was required to inform the defendant of collateral consequences such as parole eligibility, and inaccuracies or misunderstandings about parole did not render the plea involuntary. Because the defendant did not prevail on his primary claim, his argument regarding the sentencing package doctrine was moot. The Supreme Court affirmed all of the circuit court’s judgments. View "State v. Ware" on Justia Law

A minor, J.A.D., was charged as a juvenile delinquent in South Dakota after threatening to shoot a school counselor, other students, and himself, during a conversation with a school official. These statements, made at school, led staff to initiate a soft lockdown and notify law enforcement. J.A.D. left the school, was later located at his grandfather’s home, and was arrested. The State charged him with aggravated assault, simple assault, and making a terrorist threat; the aggravated and simple assault charges were presented as alternatives.The Circuit Court of the Seventh Judicial Circuit found J.A.D. not delinquent on aggravated assault, concluding the State had not established use of a deadly weapon or imminence of harm. However, the court found him delinquent on the simple assault and terrorist threat charges, determining that his statements constituted a credible threat and placed the counselor in fear, and that he threatened a crime of violence with the intent to impair a public service. For disposition, the court committed J.A.D. to the Department of Corrections, finding that less restrictive alternatives were not viable due to his prior unsuccessful treatments and risk to public safety.On appeal, the Supreme Court of the State of South Dakota reviewed whether the evidence supported findings of simple assault and making a terrorist threat, and whether commitment to the Department of Corrections was proper. The Supreme Court held that the evidence was insufficient to sustain the simple assault adjudication because J.A.D.’s threat was not imminent, but affirmed the adjudication for making a terrorist threat, finding sufficient evidence of a specific intent to substantially impair a public service. The Supreme Court also affirmed the commitment to the Department of Corrections, holding that the circuit court’s findings were not clearly erroneous and that it did not abuse its discretion. View "Interest Of J.A.D." on Justia Law

Chadwick Janes was convicted of abuse or cruelty to a minor involving his stepchild, B.S. The case arose after Janes’s stepchildren and biological child disclosed physical abuse to their mother and grandmother, prompting a police report and subsequent forensic interviews at a child advocacy center. The children described incidents such as being beaten with a belt, choked, and pushed. The State charged Janes with aggravated assault and abuse or cruelty to a minor, ultimately dismissing one count before trial.The Circuit Court of the Second Judicial Circuit in Minnehaha County, South Dakota held pretrial hearings regarding the admissibility of hearsay and other act evidence, excluding some evidence but permitting others under specific statutory exceptions. At trial, additional evidence—some previously excluded or not addressed—was admitted without objection, including a forensic interview and supplemental report. The jury acquitted Janes of aggravated assault but convicted him of abuse or neglect of a child. The circuit court sentenced Janes to ten years imprisonment with three years suspended and ordered restitution for Tanya’s lost wages and future counseling costs for the children, although the written judgment did not include counseling costs.On appeal to the Supreme Court of the State of South Dakota, Janes raised issues regarding evidentiary errors, sentencing, restitution, and ineffective assistance of counsel. The Supreme Court applied plain error review and found no prejudice from the admission of disputed evidence, as much was cumulative to trial testimony. The Court affirmed Janes’s sentence and the restitution order for Tanya’s lost wages, finding sufficient evidence of causation. However, it reversed the restitution order for future counseling expenses because the amount was unascertainable and unsupported by evidence, remanding for a proper hearing. The Court rejected the ineffective assistance claim, as no prejudice was established. View "State v. Janes" on Justia Law

The case involves a defendant who was charged with first-degree murder after the fatal shooting of an individual at a bar. The investigation initially yielded no suspect, but the defendant voluntarily approached police, admitted being present at the scene, and expressed concern about possibly doing something “bad.” Over several days, police recovered relevant evidence, including a firearm and clothing linked to the defendant, and conducted multiple interviews. After a polygraph test indicated deception, detectives confronted the defendant, leading to a confession. The defendant was subsequently indicted, and his counsel moved to suppress the confession, arguing it was coerced and a false confession.The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, denied the suppression motion, finding the confession was not the result of improper coercion. Defense counsel then disclosed a forensic psychiatrist, Dr. Manlove, as an expert on false confessions. The State objected to the admissibility of Dr. Manlove’s testimony under Daubert v. Merrell Dow Pharmaceuticals, Inc., and requested a Daubert hearing. After the hearing, the circuit court allowed Dr. Manlove’s testimony on certain general topics related to false confessions but imposed restrictions prohibiting him from relating his testimony to the specific facts of the case or opining that the defendant’s confession was coerced.The Supreme Court of the State of South Dakota reviewed the circuit court’s evidentiary ruling. Applying the abuse of discretion standard, the Court held the circuit court erred by admitting Dr. Manlove’s testimony. The Court found the proffered expert opinions lacked reliability and relevance under Rule 702 and Daubert, and that the testimony was not helpful to the jury given the restrictions imposed and absence of a reliable methodology. The Supreme Court reversed the circuit court’s order permitting the expert testimony and remanded for further proceedings. View "State V. Huante" on Justia Law

Amanda Biteler was arrested and charged with driving under the influence (second offense) and released on bond in Lincoln County, South Dakota. As a condition of her bond, she was required to participate in the 24/7 alcohol monitoring program, initially submitting in-person breath tests and later authorized to use a remote breath device. This device takes a photograph of the person submitting each breath test. On December 9, 2023, her test was flagged by the monitoring software, revealing evidence that another person may have provided the breath sample while Biteler was in front of the camera. Subsequent review identified five additional suspicious incidents. Biteler was charged with six counts of false reporting to authorities under SDCL 22-11-9(3).After a court trial in the Magistrate Court for the Second Judicial Circuit, the judge convicted Biteler for the December 9 incident and acquitted her on the remaining counts. The magistrate court found that the breath test and accompanying photograph constituted a "report" under the statute, that Biteler intentionally transmitted it to law enforcement, that the report concerned law enforcement’s official duties, and that she knew the information was false. Biteler appealed to the Circuit Court, arguing the statutory term “report” was ambiguous and did not encompass her compelled breath submissions. The Circuit Court reversed the conviction, reasoning that her submissions were not “reports” within the statute’s meaning, as they were not voluntary communications.The Supreme Court of South Dakota reviewed the case, applying de novo review to the statutory interpretation of SDCL 22-11-9(3). The court held that the term “report” under the statute is not limited to formal or voluntary communications but encompasses any transmission furnishing information to law enforcement, regardless of medium or voluntariness. The Supreme Court reversed the Circuit Court’s decision and reinstated Biteler’s conviction. View "State v. Biteler" on Justia Law

A man became the stepfather to five children after moving in with their mother on a ranch in Corson County, South Dakota. Over several years, he took on the role of disciplinarian, and his methods escalated into severe physical abuse, including shocking the children with a cattle prod, using shock collars, and physical beatings. He also provided illegal drugs to some of the children and subjected his stepdaughter to repeated sexual assaults, beginning when she was fourteen. The pattern of abuse and cruelty continued even as the family moved around the country, including periods spent in Oklahoma and Sioux Falls.After one of the children disclosed the abuse to a military recruiter, law enforcement became involved, and the man was convicted for related conduct in Minnehaha County. He was later indicted in Corson County on multiple charges: three counts of rape, three counts of aggravated assault, and five counts of abuse or cruelty to a minor. The State sought to admit evidence of similar abusive acts occurring in other jurisdictions. The defense objected, arguing these incidents were irrelevant and too remote, but after a hearing, the Circuit Court of the Fourth Judicial Circuit allowed the evidence, reasoning it showed a common plan and the nature of the familial relationship. The jury found the defendant guilty on all counts. The Circuit Court also denied the defendant’s motion for judgment of acquittal on one rape count.The Supreme Court of the State of South Dakota reviewed the case. It held that the circuit court did not abuse its discretion in admitting evidence of acts committed outside Corson County, finding such evidence admissible to show motive, plan, and the relationship between the defendant and the victims. The Supreme Court also concluded that sufficient evidence supported the second-degree rape conviction, determining that the jury could reasonably find the element of force or coercion was met. The Supreme Court affirmed the convictions. View "State v. Long" on Justia Law

A man managed his elderly mother’s finances and care after his father’s death. He was given power of attorney and access to her accounts. Over several years, he arranged for large sums to be transferred from her investment and checking accounts to support his struggling business. Additionally, he mortgaged significant parcels of the family’s farmland—held in his mother’s revocable trust—as collateral for loans used primarily for his benefit. Some of these financial moves occurred while his mother’s cognitive abilities were declining, and she was living in assisted care.After concerns about these transactions were raised by a family member, law enforcement investigated. The State charged the man with multiple counts of theft by exploitation of an elder under South Dakota law, related both to the mortgages and the transfers from his mother’s accounts. At trial in the Circuit Court of the Third Judicial Circuit, Spink County, a jury found him guilty on all counts. The circuit court imposed fully suspended penitentiary sentences and probation. The defendant appealed, arguing the evidence was insufficient to prove the elements of the crimes, and also objected to the jury instructions regarding his claimed good faith defense.The Supreme Court of the State of South Dakota reviewed the case. The court held that the evidence was sufficient for a rational jury to find that the defendant voluntarily assumed a duty to support his mother, was entrusted with her property, and appropriated her property for his own benefit with intent to defraud, not in the lawful execution of his trust. The court also determined that the jury was properly instructed on good faith and the State’s burden of proof. The Supreme Court affirmed the convictions. View "State v. Clemensen" on Justia Law

A man was convicted of three counts of sexual contact with a developmentally disabled adult neighbor, D.W., who functioned at the intellectual level of a seven-year-old. The incidents occurred during a Fourth of July celebration at the defendant’s home, involving inappropriate touching on a four-wheeler, on a hot tub, and behind a trailer. D.W. reported the incidents to his mother, who was his court-appointed guardian. The mother recorded a phone call in which the defendant made incriminating statements about the incidents. D.W. was later evaluated by a physician specializing in abuse of developmentally disabled individuals.The Circuit Court of the Second Judicial Circuit, Minnehaha County, presided over the trial. The court allowed D.W. to testify while holding a stuffed animal for comfort, over the defendant’s objection. The court denied the defendant’s motions for judgment of acquittal at the close of the State’s evidence and at the end of trial. The jury found the defendant guilty on all three counts. The defendant appealed, challenging the allowance of the stuffed animal, the sufficiency of the evidence, and two other issues not preserved for appeal: the physician’s testimony and the State’s cross-examination.The Supreme Court of the State of South Dakota reviewed the case. It held that the circuit court did not abuse its discretion in allowing D.W. to testify with a stuffed animal, as courts have broad authority to manage witness testimony and accommodations. The Supreme Court also found no plain error in the State’s cross-examination or the physician’s testimony, and concluded that sufficient evidence supported the convictions. The Supreme Court affirmed the convictions and all rulings of the circuit court. View "State v. Richter" on Justia Law