Justia South Dakota Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of second-degree and first-degree manslaughter and sentencing Defendant to life in prison on the murder conviction, holding that that the circuit court erred in one of its evidentiary rulings, but the error did not rise to the level of prejudicial error requiring reversal.On appeal, Defendant argued, among other things, that the circuit court's evidentiary rulings regarding the testimony of a particular witness and her subsequent impeachment were erroneous. The Supreme Court affirmed, holding that the circuit court (1) failed correctly to weigh the prejudicial effect of Defendant's statements made to the witness, but the error did not require reversal because it did not rise to the level of prejudicial error; (2) did not violate Defendant's right to be brought to trial within 180 days under S.D. Codified Laws 23A-44-5.1; and (3) did not err by denying Defendant's motions for judgment of acquittal. View "State v. Little Long" on Justia Law

The Supreme Court affirmed Defendant's conviction of possession of a controlled substance and several misdemeanor offenses, holding that the circuit court did not err by denying Defendant's motion to dismiss for a violation of the 180-day speedy trial rule.At issue on appeal was the circuit court's decision to exclude 102 days between the time of Defendant's first appearance and the trial in which a Minnehaha County warrant was outstanding. The Supreme Court affirmed, holding (1) the circuit court properly determined that the delay caused by Defendant's absence from Minnehaha County was attributable to him; and (2) therefore, the circuit court properly excluded the 102 days in which the Minnehaha County warrant was outstanding. View "State v. Langen" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of distributing a controlled substance and one count of possession of a controlled substance, holding that there was no prejudicial error in the proceedings below.The evidence at trial centered on the testimony of a confidential informant, who purchased methamphetamine from Defendant during a controlled drug buy. On appeal, Defendant argued, among other things, that the circuit court abused its discretion by allowing the informant to testify about other act evidence after finding that Defendant opened the door to such testimony. The Supreme Court affirmed, holding (1) even if the circuit court abused its discretion by overruling Defendant's general Rule 404(b) objection after defense counsel's question opened the door to further inquiry, the additional testimony was not prejudicial; and (2) the circuit court did not err in denying Defendant's motion for judgment of acquittal. View "State v. Nohava" on Justia Law

The Supreme Court affirmed the judgment of the sentencing court revoking Defendant's suspended sentence, holding that the sentencing court did not abuse its discretion.Pursuant to a plea agreement, Defendant pled guilty to abuse or cruelty to a minor under seven years old. The circuit court sentenced Defendant to ten years' imprisonment, suspended on multiple conditions. The State later moved to revoke Defendant's suspended sentence on the grounds that she had violated a condition of her sentence. The court concluded that Defendant had violated a condition of her suspended sentence and sentenced her to ten years but suspended five years. The Supreme Court affirmed, holding that the sentencing court did not abuse its discretion in revoking the suspended sentence. View "State v. Kari" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree rape and simple assault, holding that the circuit court did not err when it denied Defendant's motion for a judgment of acquittal on the second-degree rape charge.Specifically, the Supreme Court held (1) there was sufficient evidence to sustain Defendant's conviction for second-degree rape because there was sufficient evidence of "force" as required under S.D. Codified Laws 22-22-1(2); (2) the circuit court did not commit plain error by allowing certain testimony; and (3) the representation provided by Defendant's trial counsel was not constitutionally deficient. View "State v. Townsend" on Justia Law

The Supreme Court affirmed Defendant's convictions for second-degree murder, first-degree manslaughter, robbery, and additional offenses, holding that the circuit court did not err in overruling Defendant's objection to the inclusion of a jury instruction regarding attempted robbery or by denying Defendant's motion for judgment of acquittal and his motion to arrest judgment.Specifically, the Supreme Court held (1) the circuit court did not err by denying Defendant's motion for judgment of acquittal for second-degree murder or first-degree manslaughter, holding that the convictions were supported by the evidence; and (2) the circuit court did not err by denying Defendant's motion to arrest judgment. View "State v. Frias" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of three felony drug offenses in connection with the sale of methamphetamine to a confidential informant, holding that the circuit court did not abuse its discretion in denying Defendant's motion for a new trial and that Defendant's sentence did not constitute cruel and unusual punishment under the Eighth Amendment.After a two-day trial, Defendant was convicted of three drug-related offenses. Defendant was sentenced to fifteen years imprisonment for the possession and distribution counts, to run concurrently to each other and to the sentences he was serving, and to twenty-five years for the offense of distribution in a drug free zone, to run consecutively to his other sentences. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion by refusing to admit certain evidence proffered by Defendant; (2) the circuit court did not abuse its discretion in denying Defendant's motion for a new trial; and (3) Defendant's sentence was neither grossly disproportionate to his crimes nor cruel and unusual. View "State v. Shelton" on Justia Law