Justia South Dakota Supreme Court Opinion Summaries

Under the Fourth Amendment, law enforcement may not require an arrestee to urinate into a specimen container as a search incident to a lawful arrest without a valid warrant.Defendant was convicted and sentenced for unauthorized ingestion of a controlled substance. On appeal, Defendant argued that the circuit court erred by denying his motion to suppress evidence produced through chemical analysis of a urine sample that law enforcement obtained without first obtaining Defendant’s consent or a warrant. After considering an arrestee’s legitimate expectation of privacy and the government’s competing interest in preserving evidence, the Supreme Court agreed, holding (1) law enforcement may not, without a warrant, require an arrestee to provide a urine sample as a search incident to arrest; and (2) therefore, the search in this case was unconstitutional, and the circuit court erred by denying Defendant’s motion to suppress. View "State v. Lar" on Justia Law

The Supreme Court affirmed the circuit court order, entered after a hearing, summoning William Joseph Wilkie to appear and testify in an out-of-state criminal proceeding in Clay County, Minnesota but reversed and remanded the order summoning Wilkie’s granddaughter, M.M.W., to appear and testify in the same criminal proceeding.In this consolidated appeal, Wilkie and M.M.W. argued that their rights as victims in the criminal proceeding were violated because they were not advised of their right to counsel during the circuit court hearing. The Supreme Court affirmed in part and reversed and remanded in part holding (1) because the proceedings in South Dakota did not implicate S.D. Const. art. VI, section 29, the circuit court had no obligation to advise either Wilkie or M.M.W. of any rights under Marsy’s Law; but (2) while the circuit court did not err in finding that Wilkie failed to present any evidence of hardship for himself in ordering Wilkie to appear and testify in Minnesota, the circuit court failed to make adequate findings on M.M.W.’s claim of hardship. View "In re Issuance of a Summons Compelling an Essential Witness to Appear & Testify" on Justia Law

The Supreme Court affirmed Defendant’s convictions for first-degree murder, first-degree burglary, and second-degree rape, holding that the circuit court did not commit prejudicial error in any of the issues raised by Defendant.On appeal, Defendant argued that the circuit court committed several errors in its evidentiary rulings, erred by denying Defendant’s motions for mistrial, erred in denying Defendant’s proposed jury instructions, and erred by denying Defendant’s motion for judgment of acquittal. Defendant further argued that the accumulation of the errors constituted reversible error. The Supreme Court disagreed, holding that there was no prejudicial error. View "State v. Kryger" on Justia Law

The Supreme Court reversed the circuit court’s order rejecting the plea agreement between Defendant and the State.After Defendant and the State entered into a plea agreement the circuit court accepted Defendant’s guilty plea and the factual basis to support the plea. Two weeks later, the circuit court informed the parties that it intended to reject the plea agreement. The court then entered an order rejecting the plea agreement. Defendant appealed, arguing that the circuit court was bound by the plea agreement. The Supreme Court agreed, holding that because the circuit court at the time of the plea did not reject the agreement and did not defer its decision to accept or reject the agreement, the circuit court was required to sentence Defendant within the bounds of the plea agreement. The court remanded the case with directions to sentence Defendant in accordance with the agreement. View "State v. Hale" on Justia Law

The Supreme Court reversed the circuit court’s order rejecting the plea agreement between Defendant and the State.After Defendant and the State entered into a plea agreement the circuit court accepted Defendant’s guilty plea and the factual basis to support the plea. Two weeks later, the circuit court informed the parties that it intended to reject the plea agreement. The court then entered an order rejecting the plea agreement. Defendant appealed, arguing that the circuit court was bound by the plea agreement. The Supreme Court agreed, holding that because the circuit court at the time of the plea did not reject the agreement and did not defer its decision to accept or reject the agreement, the circuit court was required to sentence Defendant within the bounds of the plea agreement. The court remanded the case with directions to sentence Defendant in accordance with the agreement. View "State v. Hale" on Justia Law

The Supreme Court affirmed the judgment of the circuit court, rendered after a jury trial, convicting Defendant of aggravated assault (domestic) and simple assault (domestic). On appeal, Defendant challenged the circuit court’s admission of evidence of alleged instances of prior domestic abuse and claimed that his trial counsel was constitutionally ineffective. The Supreme Court held (1) the circuit court did not err in admitting the other acts evidence; and (2) counsel was not so ineffective that it deprived Defendant of his constitutional rights to counsel and a fair trial. View "State v. Phillips" on Justia Law

In 2016, Berton Toavs shot and killed his girlfriend Eliza Edgins and his friend Nathan Gann at Toavs’s home in Faith, South Dakota. Toavs and Edgins were in an off-and-on romantic relationship for some time, and Gann had been staying at Toavs’s home for approximately six weeks prior to the incident. During the time Gann had been staying with Toavs, a romantic relationship developed between Edgins and Gann. Gann and Edgins apparently planned to leave South Dakota and continue their relationship. After hearing this news, Toavs left the house, returning the following morning. Toavs and Edgins argued, ending with Toavs going to his bedroom, grabbing his .45 caliber Colt revolver, and shooting Edgins multiple times. He then shot Gann, who had been sleeping on the living room floor. Both Edgins and Gann died from the gunshot wounds. Toavs appeals his sentences issued on two counts of first-degree manslaughter, arguing the sentencing court abused its discretion in ordering him to serve two consecutive sentences of 110 and 100 years. According to Toavs, the sentencing court did not adequately consider whether Toavs was capable of rehabilitation prior to imposing the sentences. Finding no reversible error, the South Dakota Supreme Court affirmed Toavs’s sentences. View "South Dakota v. Toavs" on Justia Law

Clint Bolton was charged with alternative counts of simple assault, a class 1 misdemeanor. Pursuant to a plea agreement, the State filed an amended complaint charging disorderly conduct, a class 2 misdemeanor. Class 2 misdemeanors carry a maximum sentence of thirty days in jail or a $500 fine or both. The State also agreed to recommend a thirty-day jail sentence with all thirty days suspended. Bolton agreed to the plea agreement, and counsel entered a no contest plea to disorderly conduct on Bolton’s behalf. The magistrate court accepted the plea and imposed a thirty-day jail sentence. The court then suspended execution of that sentence on the condition that Bolton obey all laws and remain on good behavior for six months. Bolton’s attorney immediately objected to the sentence, arguing the court could not condition a suspended execution of sentence for a period longer than thirty days, the statutory maximum term of imprisonment for class 2 misdemeanors. The issue before the South Dakota Supreme Court was whether sentencing courts have the power to suspend execution of sentence on the condition of good behavior for periods longer than the authorized maximum term of imprisonment. The Court concluded sentencing courts indeed have such power because it has been delegated to them by the Constitution and the Legislature has not restricted it. View "South Dakota v. Bolton" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant’s motion for a new trial.In State v. Bausch, the Supreme Court reversed Defendant’s convictions for sexual contact and remanded the case with direction that the circuit court vacate the convictions and resentence Defendant on his four rape convictions. On remand, the circuit court vacated Defendant’s sexual contact convictions and resentenced Defendant on the four rape convictions. Defendant filed a motion for a new trial, which the circuit court denied. The Supreme Court affirmed, holding that the circuit court carried out this court’s remand directive when it vacated Defendant’s sexual contact convictions and resentenced Defendant on the four rape convictions. View "State v. Bausch" on Justia Law

The Supreme Court affirmed the sentence imposed upon Defendant to a five-year penitentiary term while Defendant was serving a probationary sentence imposed in a different criminal file. On appeal, Defendant argued that the sentencing court imposed an illegal sentence when it placed him under the dual supervision of the judicial and executive branches. The Supreme Court held (1) the sentencing court erred when it placed Defendant under simultaneous supervision of two branches of government; but (2) because Defendant was currently only under the supervision of the executive branch, the sentence was constitutional. View "State v. Humpal" on Justia Law