Justia South Dakota Supreme Court Opinion Summaries

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

While Defendant was incarcerated, he killed a corrections officer. The circuit court sentenced Defendant to death for the murder. On appeal, the Supreme Court remanded Defendant’s death sentence, concluding that the circuit court may have committed prejudicial error by improperly considering, for sentencing purposes, statements made by Defendant in a psychological evaluation procured to determine his competency to stand trial. The Court remanded for the limited purpose of resentencing without the use or consideration of the psychological evaluation unless Defendant called its authority to testify. On remand, the circuit court entered an amended judgment of conviction sentencing Defendant to death. The Supreme Court affirmed Defendant’s death sentence, holding (1) the Court’s remand directions in Berget I did not infringe upon any of Berget’s constitutional rights; (2) the limited remand did not implicate or otherwise violate Defendant’s rights to be present and to allocution; and (3) Defendant’s judicial bias argument failed. View "State v. Berget" on Justia Law

Defendant was convicted of possession of a controlled substance and ingestion of a substance for the purpose of becoming intoxicated. The Supreme Court affirmed, holding (1) a plain reading of the statutes under which Defendant was convicted reveals that nothing precludes a conviction of unauthorized possession when the controlled substance is ingested and thereby absorbed into the human body; (2) Defendant did not face double jeopardy by being convicted of both possession of a controlled substance, by way of an altered state of cocaine absorbed into the body, and ingestion of a substance other than alcohol for purposes of becoming intoxicated; (3) there was sufficient evidence to prove venue; and (4) the circuit court did not err in instructing the jury. View "State v. Whistler" on Justia Law

After drinking heavily, Defendant opened the passenger door to his truck to get a cigarette. In doing so, Defendant inadvertently bumped the gear shift, causing it to pop into neutral. The truck then rolled into a parked vehicle. Defendant was subsequently convicted of being in “actual physical control” of a vehicle while under the influence of alcohol. The Supreme Court reversed and remanded with instructions to vacate the judgment of conviction, holding that Defendant’s actions did not put him in such control as would enable him to actually operate the vehicle in its usually and ordinary manner, nor did Defendant’s actions reflect any exercise of dominion or control over the vehicle. View "State v. Nekolite" on Justia Law