Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the habeas court dismissing Appellant's application for habeas corpus relief alleging ineffective assistance of counsel, holding that there was no error.Defendant was convicted of one count of third-degree rape. On appeal, Defendant asserted that plain error occurred in the prosecutor's alleged vouching of the victim during closing argument. The Supreme Court affirmed. Defendant later filed an application for habeas corpus relief, alleging ineffective assistance of counsel (IAC) based, in part, on trial counsel's failure to object to the prosecutor's alleged misconduct. The habeas court denied relief. The Supreme Court affirmed, holding (1) the habeas court properly dismissed Defendant's IAC claim related to the prosecutor's improper vouching was res judicata; and (2) this Court lacked jurisdiction to consider Defendant's remaining IAC claim. View "Harris v. Fluke" on Justia Law

The Supreme Court affirmed the judgment of the circuit court imposing a penitentiary sentence after Defendant pleaded guilty to two felonies, holding that the State's comments at sentencing did not breach its implied obligation of good faith under the terms of the plea agreement.Pursuant to a plea agreement, Defendant pleaded guilty to one count of abuse or cruelty to a minor, in exchange for the State's recommendation for a suspended execution of sentence, and also pleaded guilty to one count of a controlled substance, in exchange for the State's recommendation of a fully suspended sentence. The circuit court accepted Defendant's guilty pleas and then sentenced her to twelve years' imprisonment with eight years suspended on the child abuse conviction. On appeal, Defendant argued that the State's sentencing argument violated the plea agreement. The Supreme Court affirmed, holding that Defendant's argument was insufficient to meet her burden under plain error review. View "State v. Guziak" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for assault by a jail inmate - contract with bodily fluids, simple assault against an inmate, and threatening a law enforcement officer, holding that there was no error or abuse of discretion.On appeal, Defendant argued that the circuit court abused its discretion by admitting a surveillance video into evidence and that the error prejudiced the outcome of his trial. Specifically, Defendant argued that a lay foundation was required under S.D. Codified Laws 19-19-901(b)(1) to authenticate the video and that that the necessary foundation was not laid in this case. The Supreme Court affirmed, holding that the evidence adequately supported the circuit court's finding that the video was an accurate recording of the incident leading to Defendant's convictions. View "State v. Reeves" on Justia Law

The Supreme Court reversed the judgment of the circuit court committing seventeen-year-old D.S. to the custody of the Department of Corrections (DOC) pursuant to S.D. Codified Laws 26-8C-7 after adjudicating him of first-degree rape, holding that the court committed reversible error because its findings and conclusions were insufficient to permit meaningful review.In announcing its disposition, the circuit court did not address whether the recommendations before it for community supervision and outpatient treatment were viable alternatives to DOC custody or whether commitment to the DOC was the least restrictive alternative in D.S.'s best interest. The day after the deposition hearing, the court entered written findings of fact and conclusions of law stating simply that there were no other viable alternatives and that commitment to the DOC was the least restrictive alternative. The Supreme Court reversed, holding that remand was required for the circuit court to make findings on the viability of a community-based supervision and treatment alternative and to reimpose a disposition consistent with the requirements of section 26-8C-7. View "In re D.S." on Justia Law

The Supreme Court affirmed the decision of the circuit court order several search warrants involving the Implicated Individual in this case and corresponding inventories to be unsealed, holding that there was no error.A special agent of the South Dakota Division of Criminal Investigation sought several search warrants involving the Implicated Individual, and the circuit court approved the warrants. The warrants, along with the supporting affidavits and inventories, were filed with the clerk of courts. At the agent's request, the circuit court sealed the search warrants but ultimately ordered that the search warrants and corresponding inventories be unsealed. The Supreme Court affirmed, holding that S.D. Codified Laws 23A-35-4.1 prohibits a court from sealing a search warrant or the verified inventory. View "In re Matter of Implicated Individual" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder but reversed the court's restitution order in part, holding that the restitution order did not comply with S.D. Codified Laws 23A-28-3.After finding Defendant guilty of second-degree murder, the circuit court imposed a mandatory sentence of life imprisonment, costs of prosecution and restitution. On appeal, Defendant argued, among other things, that the court erred in fashioning its order of restitution requiring him to pay future counseling costs and other expenses incurred by the victim's family members. The Supreme Court affirmed Defendant's conviction but reversed in part the restitution order, holding (1) the circuit court did not err in denying Defendant's motion for judgment of acquittal; (2) the circuit court did not abuse its discretion in its evidentiary rulings; and (3) the restitution order imposed arbitrary caps without specifying timeframes or mechanisms by which specific amounts to be reimbursed to the victim's family could be ascertained. View "State v. Falkenberg" on Justia Law

The Supreme Court affirmed the decision of the Department of Public Safety to disqualify Appellant's commercial driver's license (CDL) for one year after he pled guilty to driving under the influence (DUI) and received a suspended imposition of sentence, holding that the Department properly disqualified Appellant's CDL.On appeal, Appellant argued that the Department violated the doctrine of separation of powers under the state constitution by unconstitutionally infringing upon the judiciary's sentencing authority and that the Department no longer had the statutory authority to disqualify Appellant's CDL once his case was dismissed and discharged. The Supreme Court affirmed, holding (1) Appellant failed to show that South Dakota's CDL disqualification statutes violate the separation of powers doctrine in article II of the state constitution; and (2) the Department properly considered Appellant's 2016 DUI conviction for the purpose of CDL disqualification under S.D. Codified Laws 32-12A-32. View "Jans v. Department of Public Safety" on Justia Law

The Supreme Court vacated Defendant's sentence imposed in connection with his guilty plea to first-degree manslaughter, holding that the district court abused its discretion in imposing the sentence.After a confrontation with Lucas Smith at a local bar, Defendant, who was carrying a handgun, encountered Smith in a nearby alley. Smith ran toward Defendant, yelling for Defendant to shoot him. Defendant took a few steps back and then fatally shot Smith. Defendant pled guilty to first-degree manslaughter under the theory that he was "resisting an attempt by [Smith] to commit a crime." The circuit court ultimately convicted Defendant to 124 years in the penitentiary. The Supreme Court vacated the sentence, holding (1) the circuit court overlooked the element of S.D. Codified Laws 22-16-15(4) that contemplates criminal conduct by Smith, which provided partial justification for Defendant's response; and (2) the court's decision to treat Defendant as solely responsible without regard for Smith's conduct was not harmless. View "State v. Mitchell" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court denying both parties' summary judgment motions as to Plaintiff's 42 U.S.C. 1983 claims, holding that the circuit court erred in denying summary judgment in favor of the City of Sioux Falls.Plaintiff brought this action against certain officers of the Sioux Falls Police Department and the City of Sioux Falls. The police officers and the City filed a motion for summary judgment. The circuit court (1) concluded that the officers were not entitled to qualified immunity; (2) denied summary judgment on Plaintiff's claim against the City due to material issues of fact. The Supreme Court held that the circuit court (1) erred in denying summary judgment on Plaintiff's claim that the officers' warrantless entry into her apartment violated her constitutional right to be free from unreasonable searches and seizures; (2) erred in denying the City's motion for summary judgment; and (3) properly concluded that material issues of fact were in dispute on the question of whether the officers used excessive force such that Defendants were not entitled to qualified immunity as a matter of law on this section 1983 claim. View "Boggs v. Pearson" on Justia Law

The Supreme Court affirmed Defendant's conviction of driving a vehicle with alcohol in the blood in violation of S.D. Codified Laws 32-23-1(1), holding that the magistrate court's finding that Defendant provided valid, voluntary consent to the blood draw was not clearly erroneous.After law enforcement officers arrested Defendant for driving under the influence one of the officers asked Defendant if he would consent to a blood draw. Defendant twice answered, "okay," and his blood was drawn without a warrant. Defendant filed a motion to suppress, arguing that the blood draw was taken without a warrant or his valid consent. The magistrate court denied the motion. The circuit court affirmed. The Supreme Court affirmed, holding that the circuit court (1) applied the correct standard of review to the magistrate court's decision; and (2) did not err in affirming the magistrate court's decision that Defendant provided valid, voluntary consent to the blood draw. View "State v. Slepikas" on Justia Law