Justia South Dakota Supreme Court Opinion Summaries

Defendant Eric Robert pled guilty to first-degree murder for the death of penitentiary guard Ronald Johnson, a 23-year veteran correctional officer at the South Dakota State Penitentiary in Sioux Falls. Defendant waived his right to a jury’s determination of whether the death sentence would be imposed. The circuit court conducted a pre-sentence hearing and imposed the death penalty. Subsequent to pleading guilty, Defendant consistently sought imposition of the death penalty and that the execution be expedited. Even though he waived his right to appeal the death sentence, the Supreme Court was statutorily mandated to conduct a review of the sentence. Upon review, the Court found that the circuit court did not base its sentencing decision on any passion, prejudice, or any other arbitrary factor. The evidence supported the aggravating circumstances found by the circuit court, and the death sentence was neither disproportionate nor excessive when compared to other South Dakota cases in which a capital sentencing phase was conducted. The death sentence was affirmed, and the case remanded to the circuit court for entry of a warrant of execution. View "South Dakota v. Robert" on Justia Law

Defendant Courtney Koch was arrested for DUI on February 27, 2011. The magistrate judge entered an order suppressing all evidence obtained from the initial traffic stop. The State appealed to the circuit court. Defendant moved to dismiss the appeal, which the circuit court denied. The Supreme Court granted Defendant's petition for intermediate appeal. The issue was whether the circuit court had jurisdiction to entertain the State's appeal from the magistrate's order suppressing the evidence. Because the magistrate's order did not finally dispose of the case, it was not a final order appealable to the circuit court. View "South Dakota v. Koch" on Justia Law

A neighbor's complaint about marijuana directed Spearfish police officers to an apartment unit, where the officers smelled the odor of burnt marijuana outside the door. One tenant let the officers inside, but when the officers observed raw marijuana in plain view, another tenant demanded that the officers obtain a search warrant before they conducted any search. While the officers sought a warrant, they secured the apartment and detained all the tenants at the police station. On a motion to suppress, the circuit court found that the officers had probable cause to arrest two of the three tenants and search their apartment, but the detention at the station was unreasonable and violated their constitutional rights. The court suppressed all evidence. The Supreme Court granted the State's petition for intermediate appeal to consider whether the circuit court erred as a matter of law when it suppressed defendants' statements and the evidence seized under the search warrant. Upon review, the Supreme Court concluded the search was not at issue as it was "indisputably" based on a valid warrant. Further, none of the information police used to secure the warrant related in any way to the seizure of the apartment. Had the officers never seized the apartment, "but instead conducted a perimeter stakeout to prevent anyone from entering the apartment and destroying evidence, the contraband now challenged would have been discovered and seized precisely as it was here." The Court reversed the suppression order and remanded the case for further proceedings. View "South Dakota v. Tillman" on Justia Law

Defendant-Appellant Adam Olson entered into a plea agreement with the State, under the terms of which he pleaded guilty to one count of grand theft and one count of aggravated eluding of a law enforcement officer. Olson also admitted to being a habitual offender. In addition, Olson pleaded guilty to an additional count of grand theft, which the State charged him with, in a separate Information. Defendant later filed a motion to withdraw his guilty pleas. The circuit court denied his motion and sentenced him to fifteen years for the grand theft conviction and two years for the aggravated eluding of a law enforcement officer conviction. Defendant's sentence for aggravated eluding of a law enforcement officer was to run consecutive to his sentence for grand theft. The court also sentenced Defendant to serve ten years for the grand theft conviction that was charged in the separate Information. This sentence was to be served consecutive to his other sentences. Defendant appealed, raising: (1) whether the circuit court abused its discretion in denying his motion to withdraw his guilty pleas; (2) whether Defendant's sentences constituted cruel and unusual punishment under the Eighth Amendment. Upon review, the Supreme Court found no abuse of discretion nor a violation of Defendant's constitutional rights. Accordingly, the Court affirmed his conviction and sentence. View "South Dakota v. Olson" on Justia Law

A jury found Defendant Leonard Alan Toohey guilty of first degree rape of a child. On appeal, he asserts that the child victim was not available for cross-examination as required under the Confrontation Clause, that the circuit court abused its discretion when it admitted evidence of other acts, and that there was insufficient evidence to support proof of penetration. Upon review of the trial court record, the Supreme Court found that "rational jurors could [have found] proof of penetration" beyond a reasonable doubt. Accordingly, the Court affirmed Defendant's conviction. View "South Dakota v. Toohey" on Justia Law

Dennis Most was convicted in a bench trial of four counts of sexual contact with a child. Most appealed, contending (1) the trial court erred in denying his motion to exclude prior acts evidence and his motion to offer the victim's prior allegation of sexual assault, and (2) there was insufficient evidence to sustain his convictions. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion when it admitted prior acts evidence; (2) the trial court did not abuse its discretion when it denied Most's motion to offer evidence of the victim's prior allegation of sexual assault; and (3) there was sufficient evidence to sustain Most's convictions. View "State v. Most" on Justia Law

John Graham, a Canadian citizen, was convicted of felony murder and sentenced to life imprisonment without parole. Graham appealed, raising a number of arguments, including the contention that because he was extradited from Canada on a federal premeditated murder charge, under the specialty doctrine of federal extradition law, the State lacked personal jurisdiction to prosecute him on the State felony murder charge. The Supreme Court affirmed, holding (1) because Canada consented to waive specialty with respect to the state charge at issue, the State had jurisdiction to prosecute Graham for felony murder; (2) the circuit court erred in admitting certain hearsay, but the error was harmless; (3) there was sufficient evidence to sustain a finding of guilt beyond a reasonable doubt; and (4) Graham's life sentence without parole was authorized by statute and was constitutional under the Eighth Amendment. View "State v. Graham" on Justia Law

Kyle Steiner pleaded guilty to one count of sexual contact with a child and was sentenced to fifteen years in prison. Steiner subsequently filed an application for a writ of habeas corpus, claiming that his trial counsel was ineffective. Without conducting an evidentiary hearing, the circuit court dismissed the application. The Supreme Court reversed the judgment of the circuit court, holding that the circuit court was premature in dismissing Steiner's petition without conducting an evidentiary hearing on the merits, as Steiner alleged facts which, if proven to be true, would support a claim for relief, and Steiner's allegations were not unspecific, conclusory, or speculative. View "Steiner v. Weber" on Justia Law

A jury found Trent Danielson guilty of perjury. Danielson appealed, arguing that the evidence was insufficient to sustain the verdict, the trial court erred in denying his motion for a court-appointed private investigator, and the court erred in denying a motion in limine and admitting used transmission parts into evidence. The Supreme Court affirmed, holding (1) there was sufficient evidence to sustain the jury's guilty verdict, as a rational trier of fact could have found the essential elements of perjury beyond a reasonable doubt; and (2) the trial court did not abuse its discretion in denying Danielson's motion for appointment of a private investigator, motion in limine to exclude the transmission parts, and motion to dismiss for the destruction of evidence. View "State v. Danielson" on Justia Law

Appellant Ryan Rademaker was arrested for driving while under the influence of alcohol. Rademaker moved to suppress all evidence obtained from the stop of his vehicle, arguing that the stop violated his Fourth Amendment right to be free from unreasonable search and seizures. The trial court denied his motion and convicted Rademaker of driving under the influence. Rademaker appealed. The Supreme Court affirmed the trial court's ruling on the issue, holding that, based on the totality of the circumstances, the law enforcement officer had reasonable suspicion to stop Rademaker's car, and thus, the stop did not violate Rademaker's Fourth Amendment rights. View "State v. Rademaker" on Justia Law