Justia South Dakota Supreme Court Opinion Summaries

Appellant pleaded guilty to aggravated assault against a law enforcement officer. Appellant was sentenced to twenty-two years in prison. Appellant later filed a petition for writ of habeas corpus, arguing that his trial counsel provided constitutionally ineffective assistance and that his sentence was cruel and unusual punishment under the Eighth Amendment. After a hearing, the circuit court denied habeas relief. The Supreme Court affirmed, holding (1) Appellant did not receive ineffective assistance of counsel regarding his right to appeal and his right to remain silent during the presentence investigation; and (2) Appellant’s sentence was not unconstitutionally cruel or unusual. View "Stark v. Weber" on Justia Law

Appellant was convicted of possession of child pornography. The conviction was affirmed on direct appeal. Appellant later filed a pro se application for a writ of habeas corpus claiming that his jury trial was closed to the public in violation of his Sixth Amendment rights and that defense counsel’s failure to object to the closure constituted ineffective assistance of counsel. The habeas court dismissed Appellant’s application without holding an evidentiary hearing. The Supreme Court affirmed, holding that Appellant’s allegation of a Sixth Amendment public-trial violation failed to meet the “minimum threshold of plausibility.” View "Riley v. Young" on Justia Law

After a jury trial, Defendant was found guilty of second-degree murder and aggravated assault. The Supreme Court affirmed, holding (1) the trial court’s decision to instruct the jury on second-degree murder did not deprive Defendant of his constitutional right to notice of the charges against him and his right to defend against such charges where second-degree murder was not charged in the indictment; (2) the circuit court did not deny Defendant his right to confront witnesses by limiting his cross-examination of a State witness; (3) the circuit court did not err in refusing to suppress Defendant’s statements made to an officer immediately after the shooting; and (4) Defendant’s sentence for aggravated assault was not cruel and unusual in violation of the Eighth Amendment. View "State v. McCahren" on Justia Law

After a jury trial, Defendant was convicted of second-degree kidnapping and criminal trespass. Defendant appealed, arguing that the trial court erred in declining to give Defendant’s proposed instructions defining specific intent and voluntary intoxication. The Supreme Court reversed the conviction, holding (1) second-degree kidnapping is a specific intent crime, and the trial court abused its discretion by not so instructing the jury; (2) the trial court abused its discretion by denying Defendant’s proposed jury instruction related to voluntary intoxication so that the jury could properly consider his defense; and (3) Defendant was prejudiced by the trial court’s abuse of discretion. Remanded. View "State v. Liaw" on Justia Law

Defendant pleaded guilty to forgery. The circuit court accepted the plea after determining that a factual basis existed for the plea. The court sentenced Defendant without objection. Defendant appealed, arguing that the circuit court failed to obtain a factual basis that the offense occurred in South Dakota and that the adequacy of a factual basis for a plea is a jurisdictional issue. The Supreme Court affirmed, holding that an inadequate factual basis does not deprive a circuit court of its subject matter jurisdiction, and therefore, the circuit court had subject matter jurisdiction to adjudicate the case. View "State v. Sanders" on Justia Law

Defendant pleaded guilty in a South Dakota circuit court to driving under the influence and admitted to being a habitual offender. The magistrate court did not specifically inform Defendant that a guilty plea would impact his Nebraska commercial driver’s license (CDL). A year after the judgment of conviction was entered Defendant filed a motion to reopen his case and allow him to withdraw his guilty plea under S.D. Codified Laws 23A-27-11, claiming that the loss of his CDL constituted a manifest injustice. The circuit court denied Defendant’s motion. The Supreme Court dismissed Defendant’s appeal, holding that the Court did not have jurisdiction to consider the appeal because Defendant’s motion under section 23A-27-11 was not filed more than thirty days after entry of the judgment of conviction. View "State v. Kaufman" on Justia Law

Defendant was convicted of driving under the influence and having an open container of alcohol in a motor vehicle. Defendant appealed, arguing that the magistrate court and circuit court erred by failing to suppress evidence from the traffic stop that led to his convictions because the law enforcement officer lacked reasonable suspicion to initiate the traffic stop. The Supreme Court affirmed, holding that the totality of the circumstances led to a reasonable suspicion of criminal activity, and therefore, the lower courts did not err in denying Defendant’s motion to suppress. View "State v. Olson" on Justia Law

After a jury trial, Defendant was found guilty of six counts of kidnapping in the first degree, eleven counts of aggravated assault, possession of methamphetamine, and possession of methamphetamine with intent to distribute. The Supreme Court affirmed, holding (1) there was sufficient evidence to convict on the kidnapping charges; (2) the circuit court did not err in refusing to give Defendant’s proposed jury instruction on kidnapping; (3) Defendant’s challenge to the sufficiency of the evidence on the remaining charges was waived for consideration on appeal; and (4) the circuit court’s sentence did not violate the Eighth Amendment’s prohibition against cruel and unusual punishment. View "State v. Traversie" on Justia Law

Appellant pleaded guilty to first-degree murder. Appellant was sentenced to eighty years’ imprisonment and ordered to reimburse the county for costs of prosecution. Appellant later filed a petition for writ of habeas corpus, raising six issues for review. The circuit court denied the claims after an evidentiary trial. Appellant appealed, raising three issues for review. The Supreme Court affirmed, holding (1) Appellant failed to prove that his trial counsel’s performance was deficient or that Appellant was prejudiced; (2) the State did not violate the terms of the plea-bargain agreement; and (3) the sentencing court did not err by failing to advise Appellant of his Boykin rights during sentencing. View "Keinsasser v. Weber" on Justia Law

Defendant pleaded guilty to first-degree manslaughter and was sentenced to eighty years’ imprisonment with twenty years suspended. Defendant appealed, arguing that his sentence violates the Eighth Amendment’s prohibition against cruel and unusual punishment. Specifically, Defendant argued that his sentence was cruel and unusual because it was disproportionate to the sentence that his codefendant received for the same offense. The Supreme Court affirmed, holding (1) the harshness of Defendant’s sentence is not grossly disproportionate to the gravity of his offense, and although his sentence is more severe than his codefendant’s, his culpability is correspondingly greater; and (2) therefore, the circuit court did not violate the Eighth Amendment or abuse its discretion in sentencing Defendant. View "State v. Rice" on Justia Law