Justia South Dakota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of fourth-degree rape. The Supreme Court affirmed on appeal, holding (1) because the record was insufficient to allow for an appropriate review of Defendant’s argument that his trial counsel provided ineffective assistance because she did not understand S.D. Codified Laws 19-19-412; (2) the circuit court did not commit prejudicial error when it concluded that Defendant was not entitled to a hearing under section 19-19-412 because he did not file a motion for a hearing fourteen days before trial; (3) the circuit court did not abuse its discretion when it limited Defendant’s cross-examination of the victim to questions related to the victim’s sexual encounters with Defendant; and (4) the circuit court did not err when it considered Defendant’s juvenile psychological records to determine an appropriate sentence. View "State v. Golliher-Weyer" on Justia Law

Defendant was convicted of simple assault. Defendant appealed, arguing that the circuit court (1) erred in refusing to give a definitive ruling, at the close of the State’s evidence, on his request for a self-defense jury instruction; and (2) violated his constitutional right of confrontation by admitting certified copies of his fingerprint cards from prior arrests in Iowa and Nebraska. The Supreme Court affirmed, holding (1) the circuit court did not err in the manner in which it instructed on self-defense; and (2) the admission of fingerprint cards does not violate the Confrontation Clause because they are not testimonial. View "State v. Reinhardt" on Justia Law

Defendant was convicted of vehicular homicide, driving with alcohol in his blood or while under the influence of alcohol or drugs, possession of marijuana, and ingesting a non-alcoholic substance to become intoxicated. Defendant appealed, arguing that the trial court erred when in denying his motion to suppress a blood draw because law enforcement and hospital personnel took blood samples from him in violation of his constitutional rights. The Supreme Court affirmed, holding (1) blood drawn by hospital personnel for medical purposes is not subject to Fourth Amendment protection, and therefore, suppression of the draw was not warranted; and (2) exigent circumstances existed in regard to the warrantless blood draw ordered by law enforcement such that the blood draw was objectively reasonable. View "State v. Fischer" on Justia Law

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