Justia South Dakota Supreme Court Opinion Summaries

In 1996, Defendant, who was sixteen years old at the time, pleaded guilty and was sentenced to a term of thirty-three years in prison for kidnapping. In 2012, Defendant filed a pro se motion to correct an illegal sentence, arguing that his sentence was unconstitutional based on the United States Supreme Court decisions Roper v. Simmons, Graham v. Florida, and Miller v. Alabama. The circuit court denied the motion. The Supreme Court affirmed, holding that Defendant did not receive life without parole or a de facto life sentence because he had the opportunity for release at age forty-nine, and therefore, Defendant was unable to establish that Roper, Graham, and Miller applied to him. View "State v. Springer" on Justia Law

After a jury trial, Defendant was convicted of vehicular homicide and two counts of vehicular battery. The sole issue at trial was whether Defendant or the deceased was driving the Corvette when it crashed into a minivan on Interstate 90. After the Supreme Court affirmed Defendant’s convictions, Defendant petitioned successively for habeas corpus relief in state and federal courts. In his fourth amended petition for habeas relief, Defendant asserted a freestanding claim of actual innocence and newly discovered evidence through another witness. The circuit court ruled found the witness’s testimony was newly discovered, that the testimony was credible, persuasive and compelling, and that the testimony established that the witness saw a woman driving a Corvette on Interstate 90 immediately prior to the accident. The circuit court granted Defendant’s request for a writ of habeas corpus, concluding that the newly discovered evidence, in light of the evidence as a whole, would create reasonable doubt of Defendant’s guilt in the mind of a reasonable juror. The Supreme Court affirmed, holding that there was substantial evidence to support the circuit court’s conclusion that Defendant established by clear and convincing evidence that no reasonable juror would have found him guilty of the underlying offense. View "Engesser v. Young" on Justia Law

Defendant was charged with driving under the influence (DUI). A Part II Information alleged that Defendant had two prior convictions of DUI - one in 2004 and a second in 2006. Defendant filed a motion to strike the Part II Information, arguing that his 2004 DUI conviction was unconstitutional because the court neither advised him of the waiver effect of a guilty plea nor inquired into whether the plea was voluntary. The circuit court denied the motion to strike. After a trial, the circuit court entered a final judgment of conviction for third offense DUI. The Supreme Court affirmed, holding (1) a defendant may only collaterally attack prior convictions used for enhancement if he or she was unrepresented by counsel when pleading guilty; and (2) because Defendant was represented by counsel during the 2004 plea proceedings, the Court did not need to consider whether his 2004 plea was valid for enhancement purposes. View "State v. Chant" on Justia Law

Appellant pleaded guilty to possession of a controlled drug or substance. The circuit court sentenced Appellant to five years in prison with two years suspended and fined him $10,000. The two suspended years of imprisonment were conditioned on Appellant paying the fine. On appeal, Appellant argued that the $10,000 fine for possession of a controlled drug or substance was grossly disproportionate to the offense in violation of the Eighth Amendment prohibition on excessive fines. The Supreme Court affirmed, holding that Appellant failed to make a prima facie showing that the $10,000 fine was grossly disproportionate to the offense. View "State v. Webb" on Justia Law

After a jury trial, Defendant was convicted of rape and two counts of aggravated assault and sentenced to ten years in prison on each count, to be served concurrently. The Supreme Court affirmed, holding (1) the circuit court did not commit structural error by allowing the State’s reasonable doubt standard to be presented to the jurors during voir dire; (2) the State’s questioning during voir dire amounted to plain error, but Defendant’s substantial rights were not impacted by the prosecutor’s improper comments; and (3) the evidence was sufficient to support Defendant’s convictions, and therefore, the circuit court did not err in denying Defendant’s motion for judgment of acquittal. View "State v. Hayes" on Justia Law

Petitioner pleaded guilty to manslaughter in the first degree. Petitioner subsequently filed a motion to withdraw his guilty plea, which the circuit court denied. The Supreme Court affirmed the denial. Thereafter, Petitioner filed an amended and second amended application for a writ of habeas corpus, claiming that his due process rights were violated and that he was denied the right to effective assistance of counsel. The habeas court denied relief. The Supreme Court affirmed, holding (1) Petitioner’s guilty plea was voluntary and intelligent; (2) the circuit court did not abuse its discretion when it denied Petitioner’s motion to withdraw his guilty plea; and (3) Petitioner was not denied effective assistance of counsel. View "LeGrand v. Weber" on Justia Law

Defendant was convicted of first-degree arson and first-degree felony murder for intentionally setting fire to an occupied structure, resulting in the death of an unidentified victim in the fire. Defendant was sentenced to concurrent life sentences without parole for each conviction. Defendant filed a motion to correct an illegal sentence, claiming that the concurrent sentences violated the constitutional prohibition against double jeopardy. The circuit court denied Defendant’s motion. The Supreme Court affirmed, holding that the Legislature intended to authorize cumulative punishment for violations of felony murder and the underlying felony of arson, and therefore, the circuit court was authorized by the Legislature to impose concurrent sentences for both crimes. View "State v. Garza" on Justia Law

Petitioner was found guilty of several sex-related crimes and sentenced to serve an aggregate sentence of 135 years. The Supreme Court affirmed the conviction on direct appeal. Petitioner subsequently applied for writ of habeas corpus. The circuit court dismissed the application, and Petitioner moved the Supreme Court for a certificate of probable cause (CPC) to appeal the circuit court’s denial of his application. The Supreme Court reversed the habeas court’s dismissal and remanded for an evidentiary hearing. After a hearing, the habeas court entered a final order denying Petitioner’s application and motion for a CPC. Petitioner subsequently filed a motion for a CPC with the Supreme Court seeking to appeal the habeas court’s final order denying relief. The Supreme Court denied Petitioner’s motion for issuance of a CPC, holding that because Petitioner failed to address the habeas court’s findings of fact and conclusions of law, he failed to make a substantial showing of the denial of a constitutional right and therefore failed to establish probable cause that an appealable issue existed for appellate review. View "Ashley v. Young" on Justia Law

Defendant was charged with alternative counts of driving under the influence after being stopped for committing a traffic violation and having blood evidence seized from her without a warrant. Defendant filed a motion to suppress the blood test administration and results. The magistrate court granted the motion to suppress, concluding that the warrantless search conducted under the state’s implied consent statutes was unconstitutional and that the good faith exception to the exclusionary rule was inapplicable. The Supreme Court affirmed, holding (1) the blood draw in this case violated the warrant requirement of the federal constitution and state constitution; and (2) because the evidence was not obtained during a search conducted in “reasonable reliance on binding precedent,” it was not subject to the exclusionary rule. View "State v. Fierro" on Justia Law

After a jury trial, Defendant was found guilty of driving or control of a vehicle while having 0.08 percent or more of alcohol in his blood. The offense was found to be a third offense DUI within a ten-year period, and Defendant was sentenced to two years in the state penitentiary. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Defendant’s motion to suppress blood evidence seized without a warrant, as the good faith exception to the exclusionary rule applied in this case; and (2) the circuit court did not err in denying Defendant’s motion to strike a previous DUI conviction from the part II information. View "State v. Edwards" on Justia Law