Justia South Dakota Supreme Court Opinion Summaries

Kaleb Ironheart was charged with first-degree robbery and aggravated assault after stealing a bottle of liquor from a grocery store. The store manager, Francis Gergen, noticed Ironheart acting suspiciously, saw him grab a bottle of whiskey, and then watched as Ironheart ran out of the store without paying. Gergen chased Ironheart, who then pulled out a knife and threatened Gergen before escaping in a car. Ironheart was later identified and charged.Ironheart was tried in the Circuit Court of the Second Judicial Circuit, Minnehaha County, South Dakota. He moved for a judgment of acquittal on both counts, arguing that the evidence was insufficient to support either charge. The circuit court denied the motion, and the jury found Ironheart guilty on both counts. Ironheart appealed the robbery conviction, arguing that the circuit court erred in denying his motion for judgment of acquittal.The Supreme Court of the State of South Dakota reviewed the case. The court noted that under South Dakota law, robbery is defined as the intentional taking of personal property from another person's possession or immediate presence, against their will, accomplished by means of force or fear of force. The court found that a reasonable jury could have concluded that Ironheart used his knife with force or fear of force to retain possession of the liquor or to prevent Gergen’s resistance to the taking. The court also found that the jury could have concluded that the force or fear of force was not used solely as a means of escape. Therefore, the Supreme Court affirmed the lower court's decision, upholding Ironheart's robbery conviction. View "State v. Ironheart" on Justia Law

Harry David Evans, serving a life sentence for six criminal offenses including kidnapping, rape, burglary, assault, stalking, and violating a protection order, filed a writ of habeas corpus alleging ineffective assistance of counsel and violations of his rights to due process and to be free of unreasonable searches and seizures. The habeas court dismissed three of Evans' claims on the basis of res judicata as they were resolved in Evans' direct appeal. After an evidentiary hearing, the court denied the remaining claims and dismissed Evans' request for habeas relief.The Circuit Court of the Seventh Judicial Circuit in South Dakota had previously convicted Evans and his appeal was denied. Evans then filed a habeas corpus petition alleging nine claims, most of which alleged ineffective assistance of counsel. The habeas court granted the State’s motion to dismiss three of Evans’ claims on the basis of res judicata because they were effectively resolved in Evans’ direct appeal. After an evidentiary hearing, the court denied the remaining claims and dismissed Evans’ request for habeas relief.The Supreme Court of the State of South Dakota affirmed the lower court's decision. The court held that Evans' claims were resolved in his direct appeal and are barred by the doctrine of res judicata. Furthermore, Evans failed to establish that his counsel was ineffective for not calling a particular witness, not seeking to introduce cell phone records, and for not calling him to testify in his own defense. View "Evans v. Sullivan" on Justia Law

Brandon Hahn was convicted by a jury for intentional damage to property, with the damage amount totaling more than $1,000 but less than $2,500. The property in question was the front door of 88-year-old Delores Moen's home, which Hahn was accused of damaging. Hahn was also charged with obstructing a public officer and disorderly conduct, the latter of which was later dismissed. The State presented multiple witnesses, including Delores' neighbors and the responding police officers, who testified about Hahn's aggressive conduct and their interactions with him. Hahn himself denied any responsibility for damaging the door.In the Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, Hahn moved for judgment of acquittal on the intentional damage to property charge, arguing that the State had not established the fair market value of the door, which he claimed included depreciation. The court denied his motion, concluding that the State could prove the damage amount element through evidence of the cost of reasonable repairs. Hahn was found guilty on both counts and was sentenced to an enhanced 15-year prison sentence on Count 1 with ten years suspended and a 30-day jail sentence on Count 2.In the Supreme Court of the State of South Dakota, Hahn appealed, claiming that the circuit court erred when it denied his motion for judgment of acquittal on the intentional damage to property charge. He argued that the jury could not properly apply the damage element without first establishing the fair market value of the property. The Supreme Court disagreed, stating that the current version of the intentional damage to property statute focuses on the "damage to property" and not the value of the property. The court concluded that there was sufficient evidence for the jury to find that the damage Hahn caused to Delores’ door was at least $1,000 but less than $2,500, and affirmed the circuit court's decision. View "State v. Hahn" on Justia Law

Miranda Ann Henry, also known as Crystal Trinity Pumpkinseed, was sentenced to 75 years for first-degree manslaughter for the death of her boyfriend, Christopher Mexican. Henry had been released from prison on parole after serving 13 months for her fourth DUI conviction. She returned to Pierre to continue her relationship with Mexican and began using alcohol and methamphetamine. On February 8, 2022, after a week of heavy drinking, Henry decided to stop drinking. However, she began experiencing hallucinations, a condition she had suffered from since 2014. On February 9, 2022, Henry woke up next to Mexican's lifeless body, covered in blood. Law enforcement found a bloody box cutter in Henry's pocket and her blood alcohol content was 0.227%.Henry was indicted for second-degree murder. However, she entered into a plea agreement, pleading guilty to first-degree manslaughter involving domestic abuse. The State dismissed the second-degree murder charge. At the sentencing hearing, the court considered Henry's character and history, including her age, previous felony convictions, problems with alcohol abuse, and mental health issues. The court also considered the gruesome nature of the crime and the fact that Henry did not attempt to hide from law enforcement. The court sentenced Henry to 75 years with credit for time served.Henry appealed, arguing that the court abused its discretion in sentencing. She claimed that the court failed to properly weigh certain circumstances, including her unstable history, nonviolent criminal history, history with alcohol abuse, her intoxication at the time of the offense, and her mental state at the time of the offense. The Supreme Court of the State of South Dakota affirmed the lower court's decision, stating that the court did not abuse its discretion in sentencing Henry. The court had considered an extensive presentence investigation report and determined that, based on the heinousness of the offense, her prior opportunities for treatment, and her demonstrated tendency to keep committing crimes, she deserved a 75-year sentence. View "State v. Henry" on Justia Law

Brandon Scott was convicted of grand theft, a Class 5 felony, after he pled guilty to stealing a Ford F-350 pickup. The theft was part of a series of events that included breaking into a store and damaging property. Scott and the State had reached a plea agreement, which included a recommendation for a four-year "cap" at sentencing. However, the circuit court sentenced Scott to a six-year prison term with three years suspended, which Scott argued violated the terms of the plea agreement.The Circuit Court of the Second Judicial Circuit in Lincoln County, South Dakota, had initially heard the case. The court accepted Scott's guilty plea and moved on to sentencing. During the sentencing hearing, Scott's counsel requested a fully suspended prison sentence concurrent with the sentence Scott was already serving. The State, however, urged the court to impose a four-year penitentiary sentence, coupled with additional suspended time. The court ultimately imposed a six-year prison sentence with three years suspended.Upon appeal, the Supreme Court of the State of South Dakota affirmed in part, but vacated and remanded for resentencing due to the circuit court's noncompliance with SDCL 22-6-11, a statute that requires a court to sentence criminal defendants convicted of a Class 5 felony to a term of probation or a fully suspended penitentiary sentence, unless there are aggravating circumstances. The Supreme Court found that the circuit court did not err in considering itself not bound by the parties' plea agreement, nor did it err in finding there was a sufficient factual basis to support Scott's plea. However, the court did not apply the provisions of SDCL 22-6-11 during sentencing, which constituted error. View "State V. Scott" on Justia Law

The case involves James Joseph Lanpher, Jr., who pleaded guilty to two counts of aggravated assault against a law enforcement officer and admitted to being a habitual offender. The charges stemmed from a dangerous high-speed chase during which Lanpher repeatedly fired weapons at pursuing officers. The circuit court sentenced Lanpher to serve two concurrent life sentences to run consecutively to sentences he was already serving for other offenses. Lanpher appealed, claiming his sentence was cruel and unusual in violation of the Eighth Amendment and was an abuse of the circuit court’s discretion.The case was previously reviewed by the circuit court of the Third Judicial Circuit, Lake County, South Dakota. The court found Lanpher guilty and sentenced him to two concurrent life sentences, to be served consecutively to sentences he was already serving for other offenses.The Supreme Court of the State of South Dakota reviewed the case and affirmed the decision of the lower court. The court found that Lanpher's sentence did not constitute cruel and unusual punishment in violation of the Eighth Amendment. The court also found that the circuit court did not abuse its discretion in the imposition of Lanpher’s sentence. The court noted that Lanpher's violent criminal history and demonstrated disregard for human life justified the severity of his sentence. View "State v. Lanpher" on Justia Law

In October 2019, Max Bolden shot and killed Benjamin Donahue outside a club in Sioux Falls, South Dakota. Bolden was indicted for first-degree murder, second-degree murder, and possession of a firearm by a convicted felon. At trial, Bolden claimed that he shot Donahue in self-defense. The circuit court denied Bolden's motions for a judgment of acquittal on the murder charges. The jury found Bolden guilty of first-degree murder and possession of a firearm by a convicted felon. Bolden appealed his first-degree murder conviction on the grounds of insufficient evidence.The Supreme Court of the State of South Dakota affirmed the lower court's decision. The court found that there was sufficient evidence to support the jury's verdict. The court noted that Bolden had used a gun to shoot Donahue point blank in the face without provocation, and then shot him again while he was lying on the ground. The court also pointed out that Bolden had immediately left the scene, fled the state, and disposed of the gun used to shoot Donahue. The court concluded that a rational trier of fact could have found the essential elements of first-degree murder beyond a reasonable doubt. View "State v. Bolden" on Justia Law

Tristen Simonsen was convicted on two counts of solicitation of a minor, one count of sexual contact with a minor under the age of sixteen, and one count of rape in the fourth degree. The court did not specify during sentencing whether it intended to treat each charge as a separate transaction. After sentencing, the court signed four separate judgments of conviction and ordered each conviction to be served consecutively. Later the same day, the court held a hearing to clarify its intent, determining that each charge was the result of a separate transaction. Simonsen appealed, arguing that the court improperly enhanced his sentence after it had already commenced.The Supreme Court of South Dakota disagreed, ruling that the circuit court's post-sentencing declaration to treat each charge as a separate transaction only affected Simonsen's future eligibility for parole, not his sentence. The court also rejected Simonsen's argument that his constitutional rights were violated by his absence from the post-sentencing hearing, noting that the hearing only impacted his parole eligibility. The Supreme Court affirmed the circuit court's decision. View "State V. Simonsen" on Justia Law

Matthew Feucht was found guilty of possession of a controlled substance and was sentenced to nine years in prison with four years suspended. The case arose when Feucht's daughter discovered bags of marijuana in their home and alerted her mother, who then contacted the police. A search warrant was executed, leading to the discovery of firearms, ammunition, drug paraphernalia, and approximately $6,800 in small bills. Feucht was subsequently indicted on multiple charges, but under a plea agreement, he pled guilty to unauthorized possession of a controlled substance.The Circuit Court of the Second Judicial Circuit in Lincoln County, South Dakota, accepted Feucht's guilty plea and sentenced him to nine years in prison with four years suspended. Feucht appealed the sentence, arguing that the circuit court erred by imposing a penitentiary sentence without finding aggravating circumstances within the meaning of SDCL 22-6-11 and by not listing the aggravating circumstances in the judgment of conviction.The Supreme Court of the State of South Dakota agreed with Feucht's argument. The court found that the circuit court did not clearly identify on the record that it was departing from presumptive probation based on the existence of aggravating circumstances posing a significant risk to the public. Therefore, the Supreme Court vacated Feucht's sentence and remanded the case for a new sentencing hearing. View "State V. Feucht" on Justia Law

Paul Trueblood was charged with multiple offenses, including second-degree rape, following a sexual encounter with D.B.L. After a mistrial due to D.B.L. contracting COVID-19, the State presented additional evidence to a grand jury, which added charges of aiding and abetting, witness tampering, and solicitation of witness tampering. These charges were based on allegations that Trueblood arranged to have D.B.L. attacked to prevent her from testifying. On the morning of the second trial, Trueblood pled guilty to second-degree rape under a plea agreement with the State, which dismissed all other charges.Trueblood later filed a motion to withdraw his guilty plea, asserting his innocence but acknowledging that he did not immediately stop the sexual act when D.B.L. withdrew her consent. The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, denied the motion, finding that Trueblood's plea was entered knowingly and voluntarily and that he had not established any "fair and just reason" for the withdrawal.The Supreme Court of the State of South Dakota affirmed the lower court's decision. The court found that Trueblood's fear of the possible ramifications of a trial was not a sufficient reason to withdraw his guilty plea. The court also noted that Trueblood's motion was not premised on a claim of actual innocence, as he continued to admit to facts sufficient for second-degree rape. The court concluded that the lower court did not abuse its discretion by denying Trueblood’s motion to withdraw his guilty plea. View "State V. Trueblood" on Justia Law