Justia South Dakota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of six counts of child rape and six counts of sexual contact with a minor. The Supreme Court affirmed, holding (1) the evidence was sufficient to show six sexual penetrations; (2) the evidence was sufficient and to establish the county where three of the child rape counts occurred; and (3) the counts within the indictment that were identically phrased did not deprive Defendant of fair notice and the ability to defend against double jeopardy, and the record did not support a finding that the jury punished Defendant twice for one crime. View "State v. Hernandez" on Justia Law

After a jury trial, Defendant was convicted of one count of second-degree burglary and four counts of identity theft. Defendant subsequently pleaded guilty but mentally ill to grand theft. Defendant appealed, challenging both his jury convictions and the sentences imposed for each of his crimes. The Supreme Court affirmed, holding (1) the performance of defense counsel did not clearly deprive Defendant of his constitutional rights to counsel and a fair trial; (2) Defendant’s sentence did not violate the Eighth Amendment’s prohibition against cruel and unusual punishment; and (3) the circuit court did not err by denying Defendant’s motion for judgment of acquittal on the charges of second-degree burglary and identity theft. View "State v. Chipps" on Justia Law

After a jury trial, Defendant was convicted of possession of methamphetamine, possession of two ounces or less of marijuana, and possession of drug paraphernalia. The Supreme Court affirmed, holding (1) the circuit court did not err when it denied Defendant’s motion to suppress evidence of methamphetamine presented to the jury, as (i) Defendant did not preserve his arguments regarding the validity of his arrest and the subsequent search of his person, and (ii) the search of Defendant’s vehicle was constitutional; and (2) the jury was presented with sufficient evidence to conclude beyond a reasonable doubt that Defendant knowingly possessed methamphetamine. View "State v. Fischer" on Justia Law

A jury convicted Defendant of first-degree manslaughter by means of a dangerous weapon, vehicular homicide, vehicular battery, and driving under the influence. For reasons unrelated to this appeal, the Supreme Court reversed and remanded for a new trial. The State and Defendant subsequently entered into a plea agreement under which Defendant pleaded guilty to one count of first-degree manslaughter and one count of vehicular battery. After the scheduled sentencing, Defendant filed a motion to withdraw her plea. The circuit court denied the motion. Defendant appealed, arguing that the circuit court abused its discretion by denying her motion to withdraw her guilty plea because she was unable to recall committing the crimes for which she was convicted and pleaded guilty out of fear. The Supreme Court affirmed, holding that, under the circumstances of this case, the circuit court did not abuse its discretion by denying Defendant’s motion to withdraw her guilty plea. View "State v. Kvasnicka" on Justia Law

Defendant was convicted of three counts of sexual contact and rape involving three minors. The Supreme Court affirmed, holding (1) the trial judge did not cause structural error because he left the courtroom during the presentation of evidence, and Defendant was not prejudiced by the judge’s absence; and (2) the trial judge failed to fully and regularly admonish the jury at each recess and adjournment pursuant to S.D. Codified Laws 23A-24-5, but because Defendant was not prejudiced as a result of this error, his challenge to his conviction on this ground was denied. View "State v. Arguello" on Justia Law

Defendant was charged with two counts of first-degree rape and two counts of possession of child pornography. Defendant moved to suppress his admissions that he raped a three-year-old girl, arguing that the State could not present independent corroborating evidence showing the corpus delicti of a rape.The circuit court suppressed Defendant’s admissions, reasoning that there was insufficient independent evidence corroborating Defendant’s admissions. The Supreme Court affirmed, holding (1) as an alternative method of corroborating admissions alongside requiring evidence of the corpus delicti, this Court now allows evidence of the admission’s trustworthiness to corroborate the admission and establish guilt; but (2) the application of the trustworthiness rule in this case would violate Defendant’s due process right to fair warning. Remanded. View "State v. Plastow" on Justia Law

In 2001, Appellant pleaded guilty to third-degree burglary and possession of burglary tools. In 2007, Appellant was granted parole. After his release, Appellant committed another burglary in Minnesota and was convicted of second-degree burglary and possession of burglary tools. In 2012, Appellant and was re-incarcerated in South Dakota for violating his parole. Appellant filed an application for a writ of habeas corpus, alleging that his penitentiary sentences were miscalculated. The habeas court denied Appellant’s application. The Supreme Court affirmed after analyzing the statutes relevant to this appeal, holding that Appellant was correctly sentenced. View "Dale v. Young" on Justia Law

In 2014, the Supreme Court vacated Defendant’s conviction of aggravated theft by deception, holding that the State failed to prove all the elements of the offense. The State subsequently brought new charges against Defendant for forgery and offering false or forged instruments for filing, registering, or recording in a public office. Defendant moved to dismiss the charges, asserting that double jeopardy, collateral estoppel, and res judicata barred the State’s subsequent prosecution because the State had a full and fair opportunity to litigate the newly-indicted charges during the first trial. Defendant further asserted that the indictment should be dismissed for improper venue. The circuit court denied the motion to dismiss, and a jury subsequently found Defendant guilty of all charges. The Supreme Court affirmed, holding (1) because the newly-indicted charges were separate and distinct from the charges dismissed in the first trial, the State was not precluded from retrying Defendant under double jeopardy and res judicata principles; and (2) there was sufficient evidence for the jury to have concluded that venue was proper on all charges. View "State v. Thomason" on Justia Law

In 2014, Defendant admitted to violating the terms of his probation, and the circuit court revoked probation and imposed a sentence of two years incarceration (Sentence 1). That same year, Defendant received two additional sentences, each for unauthorized ingestion of a controlled drug or substance. On one of the convictions, the trial court sentenced Defendant to five years incarceration, suspended, and placed Defendant on probation (Sentence 2). On the final sentence, the court sentenced Defendant to four years incarceration (Sentence 3). The court ordered Sentence 3 to run consecutively to Sentence 1 and ordered Sentence 2 to run concurrently with Sentences 1 and 3. The Supreme Court reversed, holding that Defendant’s sentences improperly placed him under simultaneous supervision of the executive and judicial branches. Remanded. View "State v. Orr" on Justia Law

Defendant was searched pursuant to a search warrant with an “all persons” provision. Defendant was found in possession of marijuana and methamphetamine. Defendant was subsequently convicted of possession of a controlled substance and possession of marijuana. Prior to trial, Defendant moved to suppress evidence obtained a result of the search, arguing that the affidavit in support of the search warrant lacked probable cause for the “all persons” provision. The circuit court denied the motion, concluding that the affidavit adequately established probable cause for issuance of a warrant with the “all persons” provision. The Supreme Court affirmed, holding that the officers’ good-faith reliance on the warrant, specifically its “all persons” provision, was objectively reasonable, thereby making suppression an inappropriate remedy. View "State v. Running Shield" on Justia Law