Justia South Dakota Supreme Court Opinion Summaries

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

Soloman Longchase was charged with multiple offenses, including aggravated assault (domestic), aggravated kidnapping, grand theft, interference with emergency communication, and false impersonation to deceive law enforcement, stemming from incidents on August 20, 2022. After the initial complaint and indictment, Longchase was held in the Hughes County Jail on unrelated charges. He was granted a medical furlough but failed to return, resulting in an escape charge and a period as a fugitive until his rearrest in December 2023. He later appeared in court for the Hyde County charges, was appointed counsel, and ultimately entered a plea agreement to plead guilty to grand theft and simple assault, with other charges dismissed.The Circuit Court of the Sixth Judicial Circuit, Hyde County, presided over the case. Longchase moved to dismiss the indictment, alleging a violation of his constitutional right to a speedy trial. The circuit court denied the motion after applying the Barker v. Wingo factors. At sentencing, the court ordered Longchase to reimburse the county for court-appointed attorney fees, finding he had the ability to work and pay after release from prison. Longchase objected, arguing the court was required to make specific findings about his ability to pay and that recoupment was unconstitutional given his current financial status.The Supreme Court of the State of South Dakota reviewed the case. It held that Longchase’s unconditional guilty plea waived his right to appeal the alleged speedy trial violation, as the right to a speedy trial is not a jurisdictional defect that survives a guilty plea. The court also held that the circuit court’s order requiring reimbursement of attorney fees did not violate Longchase’s constitutional rights to counsel or due process, as he was afforded counsel at all critical stages and had a meaningful opportunity to contest the recoupment order. The Supreme Court affirmed the circuit court’s rulings. View "State v. Longchase" on Justia Law

The case concerns the conviction of Dion Bordeaux for first-degree murder following the shooting death of his girlfriend, Jeanette Jumping Eagle, in a Rapid City hotel room on January 1, 2020. Only Bordeaux and his brother Giovanni were present at the time of the shooting. Giovanni testified that Bordeaux and Jeanette had been arguing, and after hearing a gunshot while in the bathroom, he saw Bordeaux panicking. Bordeaux called 911, claiming Jeanette shot herself. Law enforcement found Jeanette deceased with a gunshot wound, her hand on a handgun, and evidence of blood transfer and gunshot residue. Bordeaux was arrested on an unrelated aggravated assault charge from September 2019, which later became central to the case.The Seventh Judicial Circuit Court, Pennington County, presided over the trial. The State sought to admit evidence of Bordeaux’s prior aggravated assault against his cousin, arguing it showed intent and a common scheme. The circuit court allowed this evidence, finding similarities between the two incidents. At trial, the State presented extensive forensic evidence and testimony, including details of the prior assault. Bordeaux’s defense argued that Jeanette’s death was a suicide, not homicide, and objected to the admission of the prior assault evidence, claiming it was prejudicial and not sufficiently similar to the charged offense.The Supreme Court of South Dakota reviewed the case. It held that the circuit court abused its discretion by admitting the prior aggravated assault evidence, finding insufficient similarity between the two incidents to justify its use for proving intent or a common scheme. The Court further determined that the admission of this evidence was prejudicial, as it was a significant part of the State’s case and likely influenced the jury’s verdict. The Supreme Court reversed Bordeaux’s conviction and remanded the case for a new trial. View "State v. Bordeaux" on Justia Law

A defendant was charged with possession of a controlled substance, specifically Delta-9 Tetrahydrocannabinol, and possession of drug paraphernalia. The suspected drug was sent to the state health lab for testing shortly after the charges were filed. Over the following months, the defendant’s attorney requested several delays in the trial and plea deadlines, citing the absence of a plea offer and the need for time to discuss the offer once received. Eventually, the parties reached a plea agreement, but at the change of plea hearing, the State had still not received the drug test results. The defendant then moved to dismiss the charges, arguing that the nearly seven-month delay in obtaining the test results was excessive.The Circuit Court of the Second Judicial Circuit, Minnehaha County, granted the defendant’s oral motion to dismiss, finding that the delay in obtaining the drug test results and the State’s failure to meet court-imposed plea offer deadlines constituted unnecessary delay under SDCL 23A-44-3. The court dismissed the indictment without prejudice, basing its decision solely on the statute addressing unnecessary delay in prosecution, and not on the 180-day rule for bringing a defendant to trial.The Supreme Court of the State of South Dakota reviewed the case and reversed the circuit court’s decision. The Supreme Court held that the record did not support a finding of unnecessary delay attributable to the State, as the State had submitted the evidence for testing promptly and the prosecution had not been dormant. The Court clarified that SDCL 23A-44-3 provides discretionary authority to dismiss for unnecessary delay, but the circumstances here did not justify such a dismissal. The Supreme Court reversed the dismissal and remanded the case for further proceedings. View "State v. Bradshaw" on Justia Law