Justia South Dakota Supreme Court Opinion Summaries

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

Defendant was attacked during a drug transaction. Defendant used lethal force against one of the perpetrators with an illegal shotgun. After a jury trial, Defendant was convicted of first-degree manslaughter, possession of a controlled weapon, and distribution of a controlled substance to a minor. The circuit court sentenced Defendant to forty-five years’ imprisonment. The Supreme Court affirmed in part and remanded in part, holding that the circuit court (1) did not abuse its discretion in instructing the jury on a reduced mens rea of recklessness of the charge of first-degree manslaughter or in permitting jury instructions that emphasized the illegality of the firearm; (2) did not abuse its discretion in denying Defendant’s proposed jury instructions; (3) did not fail to properly instruct the jury as to the alleged felonies being committed upon Defendant; and (4) did not abuse its discretion by admitting other-act evidence. However, because there was no way to determine if a Brady violation occurred with regard to certain evidence that was not within the record, the case was remanded for the circuit court to include the evidence within the record and to reconsider the Brady issue as to that evidence. View "State v. Birdshead" on Justia Law

Defendant pleaded guilty to possession of a controlled substance. Defendant was entitled to presumptive probation unless the court found aggravating circumstances “that pose a significant risk to the public.” In imposing sentence, the court concluded that three aggravated circumstances overcame presumptive probation and sentenced Defendant to thirty-six months in prison with eighteen months suspended. The Supreme Court affirmed, holding (1) the aggravating circumstances demonstrated that placing Defendant on probation would have posed a significant risk to the public, and therefore, the circuit court did not abuse its discretion in departing from presumptive probation; and (2) the trial court erred in not restating the aggravating circumstance in the judgment, but this clerical failure may be corrected on remand to include the omitted material in the judgment. View "State v. Beckwith" on Justia Law

Defendant pleaded guilty to first-degree rape and was sentenced to seventy years’ imprisonment. Defendant did not appeal his conviction or sentence. Approximately five years later, Defendant filed a petition for habeas relief arguing, among other things, that his guilty plea was unconstitutional because the sentencing court did not properly advise him of his right against self-incrimination or that a guilty plea would waive that right. The habeas court denied relief, finding that Defendant was properly advised of his constitutional rights. The Supreme Court affirmed, holding that the habeas court did not err in concluding that Defendant failed to establish by a preponderance of the evidence that he did not knowingly and voluntarily enter his plea. View "Oleson v. Young" on Justia Law