Justia South Dakota Supreme Court Opinion Summaries

Defendant was twenty-six years old when she was involved in a high-speed pursuit that resulted in life-threatening injuries for a highway patrolman. Defendant pleaded guilty to driving under the influence (DUI) and aggravated assault against a law enforcement officer. Defendant admitted to the part II informations filed for both offenses. Defendant received an aggregate sentence of 42.5 years. Defendant appealed, arguing that her sentence was grossly disproportionate to her crime in violation of the Eighth Amendment. The Supreme Court affirmed, holding that the circumstances of this case failed to suggest gross disproportionality. View "State v. Coleman" on Justia Law

Police officer Robert Neisen arrested Defendant for driving under the influence. Officer Niesen first informed Defendant that he had impliedly consented to a blood draw by virtue of operating a vehicle in South Dakota, but then the officer asked Defendant if he consented to the blood draw. Defendant consented. Defendant subsequently moved to suppress the blood test, arguing that his consent was not voluntary. The circuit court agreed with Defendant and suppressed the blood test. The Supreme Court affirmed, holding that the totality of the circumstances supported a conclusion that Defendant’s consent was involuntary. View "State v. Medicine" on Justia Law

Defendant pleaded guilty to one count of attempted first-degree murder and was sentenced to the maximum term of twenty-five years imprisonment. The Supreme Court affirmed, holding (1) Defendant’s sentence, which was not grossly disproportionate to Defendant’s crime, fell within the constitutional prescriptions of the Eighth Amendment; (2) the inclusion of the federal presentence investigation report in the state presentence investigation report did not violate Defendant’s due process rights; and (3) Defendant was not improperly denied counsel during his interview with court services, as Defendant did not have a Sixth Amendment right to have counsel present at the interview. View "State v. Garreau" on Justia Law

Defendant was convicted of possessing methamphetamine and sentenced to three years imprisonment. Defendant appealed, arguing that the circuit court erred in denying his motion to suppress methamphetamine evidence obtained during a “stop and frisk” because the police officer who initiated the stop lacked a reasonable basis to conclude that Defendant had committed a crime. The Supreme Court reversed, holding that the circuit court erred in denying Defendant’s motion to suppress because the officer did not have a reasonable suspicion of criminal activity, and therefore, the drug evidence was the product of an illegal search. View "State v. Walter" on Justia Law

Defendant was charged with possession of a controlled substance with intent to distribute (Count 1), possession of a controlled substance (Count 2), possession of marijuana (Count 3), and possession of drug paraphernalia (Count 4). The circuit court granted Defendant’s motion for a judgment of acquittal with respect to Count 1. However, because the dismissed Count 1 was listed in the final jury verdict form, the jury found Defendant guilty of that charge. The jury also convicted Defendant of Count 2 and Count 4 and acquitted him of Count 3. The court imposed a penitentiary sentence for Count 2 after finding grounds to depart from a presumptive sentence of probation under S.D. Codified Laws 22-6-11. The Supreme Court affirmed but remanded for entry of an amended judgment, holding (1) the trial court did not abuse its discretion when it admitted two text messages suggesting that the sender wanted to obtain cocaine from Defendant; (2) the incorrect verdict form did not affect Defendant’s substantial rights or the outcome of the trial; and (3) the court did not err by finding aggravating circumstances justified a departure from the probationary sentence mandated by 22-6-11, but the dispositional order must be amended to include the aggravating circumstances considered. View "State v. Whitfield" on Justia Law

As part of a plea agreement, Defendant pleaded guilty to possession of methamphetamine. After a sentencing hearing, the district court sentenced Defendant to five years in the penitentiary. The Supreme Court affirmed, holding (1) the totality of the circumstances established that Defendant entered his guilty plea voluntarily, knowingly, and intelligently; and (2) Defendant’s constitutional rights were not violated when the circuit court sentenced him to the maximum sentence of five years imprisonment, as the sentence was not grossly disproportionate to the offense committed. View "State v. Moran" on Justia Law

After a jury trial, Defendant was convicted of first-degree rape and sexual contact involving a child. During the trial, the trial judge, on his own initiative, and without a preclosure hearing, closed the courtroom during the victim’s testimony. The jury found Defendant guilty of both charges. After trial, the State moved to supplement the record with facts and reasons for the closure. Defendant moved for a new trial based on the closure. The circuit court granted the State’s motion and denied Defendant’s motion for a new trial. Following a hearing, the court entered findings of fact and conclusions of law supporting closure. The Supreme Court affirmed, holding (1) the circuit court’s error in not having a preclosure hearing to determine whether closure was justified did not require a new trial; and (2) the circuit court made adequate findings demonstrating an overriding interest that was no broader than necessary, considering the alternatives, for courtroom closure during the victim’s testimony. View "State v. Slota" on Justia Law

After a jury trial, Defendant was convicted of threatening or intimidating a judicial officer, offering a false instrument for filing, and uttering simulated process. The Supreme Court affirmed, holding (1) despite an error in Section A of the brief filed pursuant to State v. Korth on Defendant’s behalf, the unique posture of this case permitted the Court to review his Section B claims of error; and (2) there were sufficient facts for a jury to convict Defendant for threatening or intimidating a judicial officer, offering a false instrument for filing, and uttering simulated process. View "State v. Paulson" on Justia Law

Appellant pleaded guilty to two charges of second degree robbery. The circuit court sentenced Appellant to a term of seven years with two years suspended for the first conviction and a term of eight years with two years suspended for the second conviction. While incarcerated, Appellant signed a suspended sentence supervision agreement. After Appellant received four major rule violations, the Board of Pardons and Paroles concluded that Appellant had violated the conditions of the agreement and ordered that the suspended sentence for the first robbery conviction be revoked and imposed and that the suspended sentence for the second robbery conviction be revoked, imposed, and re-suspended. The Supreme Court affirmed, holding (1) the Board did not exceed its authority in imposing additional conditions that were “not inconsistent” with those placed by the sentencing court; and (2) Appellant failed to establish an equal protection violation because he was not treated differently than a similarly-situated class of inmates. View "Mann v. S.D. Bd. of Pardons & Paroles" on Justia Law

After a jury trial, Defendant was convicted on two counts of intentional damage to property and one count each of reckless burning, possession of a controlled substance, and possession of marijuana. The Supreme Court (1) reversed and remanded for a new trial on the intentional damage charges so that a jury may determine Rosales’s intent, holding that the circuit court erred in failing to dismiss the intentional damage charges where the jury did not determine whether Defendant acted with intent to destroy the vehicles; and (2) affirmed as to the remainder of the judgment, holding that the circuit court did not err in denying Defendant’s motion to quash the search warrant and suppress the evidence. View "State v. Rosales" on Justia Law