Justia South Dakota Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of first-degree manslaughter, commission of a felony with a firearm, and possession of a controlled weapon. Defendant appealed, arguing, inter alia, that the State committed a violation of Brady v. Maryland when it denied Defendant access to certain records. The Supreme Court issued a limited remand to determine whether a Brady violation occurred in this case and to include the records in the record. On remand, the circuit court concluded that the State committed no Brady violation as it pertained to the challenged records. The Supreme Court affirmed, holding (1) the circuit court did not err when it concluded that the State committed no Brady violation; and (2) the circuit court did not err in determining that Defendant was not entitled to a new trial related to the subject records. View "State v. Birdshead" on Justia Law

Defendant pleaded guilty to one count of aggravated incest and four counts of abusing his children. Defendant was sentenced to a total of forty-seven years imprisonment and ordered to pay the Department of Social Services $19,555 for counseling and treatment costs incurred in caring for the children. Defendant appealed from the reimbursement order, contending that the Department was not statutorily entitled to the reimbursement order because it was not a victim of Defendant’s crimes. The Supreme Court affirmed, holding that, even if the Department did not qualify as a victim under S.D. Codified Laws 23A-28-2(5), Defendant was still responsible for paying the entirety of his victims’ treatment costs under S.D. Codified Laws 23A-28-12. View "State v. Jones" on Justia Law

In this case, the Supreme Court held that the question of whether a defendant is “licensed or privileged to enter or remain” in an occupied structure hinges on whether the defendant is, under the totality of the circumstances, in possession or control of the premises at the time of entry. Defendant entered a home he previously shared with his ex-wife and brought with him items that could be used for restraint, a suicide note, and his last will and testament. The police arrested Defendant inside the home, and the State charged with second-degree burglary, among other offenses. Defendant ultimately pleaded guilty to second-degree burglary. Defendant moved to withdraw his plea, which the circuit court denied. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Defendant’s motion to dismiss on the grounds that he had a “license or privilege to enter or remain” in the residence under S.D. Codified Laws 22-32-3; (2) did not abuse its discretion in denying Defendant’s motion to set aside the judgment of conviction and allow withdrawal of Defendant’s guilty plea; and (3) did not err by accepting Defendant’s guilty plea where there was an adequate factual basis supporting Defendant’s guilty plea. View "State v. Pentecost" on Justia Law

Defendant was charged with murder and kidnapping. Defendant was a juvenile at the time of the crime. The State moved to transfer Defendant’s case to adult court. After a hearing, the juvenile court granted the State’s motion to transfer. After a trial in adult court, the jury found Defendant guilty of first-degree murder (arson), first-degree felony murder, first-degree arson, felony murder (aggravated kidnapping), and second-degree aggravated kidnapping. Defendant was sentenced to eighty years imprisonment for the murder conviction and a concurrent fifty-year sentence for second-degree aggravated kidnapping. The Supreme Court affirmed, holding (1) the juvenile court did not err in transferring Defendant to adult court; (2) the circuit court did not fail to adequately instruct the jury on Defendant’s theory of defense; and (3) Defendant’s eighty-year-sentence was not an abuse of discretion, grossly disproportionate, or a de facto life sentence in violation of the spirit of Montgomery v. Louisiana. View "State v. Diaz" on Justia Law

Defendant was indicted for eight drug-related offenses. After a jury trial, Defendant was convicted of seven of the eight counts. Defendant appealed, arguing (1) the trial court erred by amending the indictment the day before trial, and (2) the trial court committed plain error by not informing the parties of a jury question that arose during deliberations and then by answering that question without input from the parties. The Supreme Court affirmed, holding (1) the trial court did not commit plain error by amending the indictment the day prior to trial; and (2) the trial court did not commit plain error by not notifying the parties of the jury’s question at the time it occurred. View "State v. Schrempp" on Justia Law

Defendant was arrested and charged with driving under the influence after police officers approached a parked vehicle and found Defendant in the driver’s seat and smelled the odor of alcohol. Defendant filed a motion to suppress, asserting that the officer did not have reasonable suspicion to support the intrusion. The circuit court denied the motion to suppress, holding that the officer’s investigation was justified under the community caretaker exception to the warrant requirement. The Supreme Court affirmed, holding that the circuit court did not err when it concluded that the community caretaker exception to the warrant requirement applied and thus denied Defendant’s motion to suppress. View "State v. Kleven" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated assault. Defendant was sentenced to twenty years in the state penitentiary. Defendant appealed, arguing that the trial court erred by allowing a nurse practitioner who helped care for the victim to give her opinion regarding the seriousness of the victim’s injuries. The Supreme Court affirmed, holding that the circuit court did not err, let alone commit plain error, in permitting the nurse practitioner to opine whether the victim suffered a serious bodily injury, and therefore, Defendant was not deprived of a fair trial by jury. View "State v. Greenwood" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The circuit court sentenced Defendant to life imprisonment without parole. Defendant appealed, challenging the circuit court’s denial of his motion to suppress. Specifically, Defendant argued that the court erred when it found that exceptions to the warrant requirement existed and erred by failing to suppress his statements made to law enforcement prior to receiving Miranda warnings. The Supreme Court affirmed, holding (1) exigent circumstances existed justifying the officers’ warrantless entry of Defendant’s apartment; and (2) the admission of Defendant’s statements that he made to law enforcement before he received Miranda warnings was proper. View "State v. Rogers" on Justia Law

In 2007, Appellant pleaded guilty to two counts of possession of child pornography and admitted that he was a habitual offender. Appellant did not directly appeal his conviction. Nearly seven years after his conviction became final, Appellant filed a petition for a writ of habeas corpus, alleging multiple claims of ineffective assistance of counsel and a Miranda violation. After a hearing, the habeas court concluded that Appellant’s habeas petition was untimely and granted the State’s motion for summary judgment, dismissing Appellant’s petition with prejudice. The Supreme Court reversed, holding (1) the habeas court did not err in applying S.D. Codified Laws 21-27-3.3 to Appellant’s action because Appellant commenced the action after the effective date of the statute; but (2) in applying section 21-27-3.3, the habeas court had the authority to delay commencement of the two-year limitations period until the effective date of the statute, and because Appellant filed the action within the two years, the habeas court erroneously granted summary judgment against Appellant for violating the statute of limitations in section 21-27-3.3. View "Hughbanks v. Dooley" on Justia Law

Defendant was indicted with one count of second-degree rape. During his trial, Defendant requested access to summaries written by the prosecutor or by others in the prosecutor’s office documenting the victim’s oral declarations about the alleged rape, claiming that the notes were discoverable under S.D. Codified Laws 23A-13-10(4). The trial court concluded that the prosecutor’s notes were protected attorney work product and did not fall under section 23A-13-10. The jury subsequently found Defendant guilty of rape. The Supreme Court reversed, holding that Defendant was entitled to have notes in the possession of the prosecutor containing summaries of the victim’s prior statements related to the allegations against Defendant produced for an in camera review by the circuit court to determine if those notes contain statements discoverable under section 23A-13-10(4). If the court concludes that the notes contain discoverable statements under section 23A-13-10 that could have affected the outcome of the trial, the court is directed to vacate Defendant’s conviction and order a new trial. View "State v. Horned Eagle" on Justia Law