Justia South Dakota Supreme Court Opinion Summaries

Rylan Walth was convicted of one count of possession with intent to distribute and one count of simple possession of a controlled drug. Prior to trial, Walth filed a motion to suppress a statement he made to a police officer on the grounds that his Miranda rights were violated. The trial court denied the motion to suppress. The Supreme Court affirmed the denial of the motion to suppress, holding (1) the statements Walth made to a detective prior to his arrest were not made while he was in custody because a reasonable person would have understood he or she was at liberty to terminate the interview and leave; and (2) therefore, there was no Miranda violation. View "State v. Walth" on Justia Law

Christopher Fisher was convicted of manslaughter following the death of a fifteen-month-old child. Fisher appealed, contending that the trial court erred in (1) failing to suppress incriminating statements Fisher made during an interview with law enforcement, (2) admitting a portion of a videotaped interrogation where Fisher was depicted shaking a doll with the image of the doll redacted; and (3) finding that one of the state's expert witnesses was qualified to testify about abusive head trauma. The Supreme Court affirmed, holding (1) Fisher's confession during his interrogation was voluntary, and the trial court did not err in denying his motion to suppress; (2) the trial court did not err in admitting the redacted video of Fisher shaking the doll as the evidence was insufficient to mislead the jury or unfairly prejudice Fisher; and (3) the trial court did not abuse its discretion in allowing the expert witness to testify because the evidence in the record supported the trial court's conclusion that the witness had sufficient knowledge, training or education to offer her opinion on the child's cause of death. View "State v. Fisher" on Justia Law

Lacy March sought a protection order against Roger Thursby, which the circuit court granted. The testimony elicited at trial concerned stalking. Thursby appealed, alleging, among other things, that the findings of fact were insufficient to support the order as signed. The Supreme Court reversed due to insufficiency of the findings of fact, holding the circuit court failed to insure that the findings of fact and conclusions of law were clearly entered. Specifically, the Court found that although the circuit court indicated that it believed March's version of the events, the written finding did not correspond with the oral testimony of March, and the court did not indicate how the evidence met the statutory elements of stalking. View "March v. Thursby" on Justia Law

Lucas Waugh was charged with attempted rape of a woman and the rape of a minor. The incidents occurred one after the other within walking distance of each other. The circuit court joined the cases for trial, and a jury found Waugh guilty of both offenses. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in joining the charges for trial because (i) the two incidents in this case were closely related in time, location, and manner of execution, and (ii) there was no undue prejudice because the evidence of each incident could have been admitted in the trial of the other; and (2) the evidence was sufficient for a reasonable trier of fact to have found Waugh guilty of both offenses. View "State v. Waugh" on Justia Law

Defendant Christopher Jones was convicted of raping a twenty-three-year-old woman who testified that she was too intoxicated to have consented. The defendant appealed, asserting that although S.D. Codified Laws 22-22-1(4) does not explicitly include a knowledge element, the circuit court erred when it failed to instruct the jury that the State must prove that the defendant knew that the woman's intoxicated condition made her unable to consent. The Supreme Court reversed, holding that the Legislature intended that a rape conviction under section 22-22-1(4) requires proof that the defendant knew or reasonably should have known that the victim's intoxicated condition rendered her incapable of consenting. Remanded for a new trial. View "State v. Jones" on Justia Law

Appellant Mil Hirning pleaded guilty to unauthorized possession of a controlled substance and admitted to being a habitual offender. Hirning made the plea after Hirning's trial counsel withdrew from representing him and Hirning proceeded pro se. On appeal, Hirning argued that his waiver of counsel was not voluntary, knowing, and intelligent. The Supreme Court reversed Hirning's convictions and sentence, (1) finding that Hirning was not warned of the dangers of self-representation, and (2) holding that the record did not indicate circumstances from which the Court could find Hirning was aware of the danger and made a voluntary, knowing, and intelligent waiver. Remanded. View "State v. Hirning" on Justia Law

Petitioner Dale Guthmiller was convicted of criminal pedophilia and sentenced to life in prison. Petitioner subsequently petitioned the circuit court for a writ of habeas corpus, alleging, among other things, that the trial judge made improper comments during the trial, violating Petitioner's constitutional right to a fair trial. The habeas court granted Petitioner's writ on reconsideration, (1) concluding that the trial judge's comments created a structural error negating Petitioner's requirement to establish prejudice, and (2) retracting its earlier ruling that trial counsel's failure to object was not prejudicial. The Supreme Court reversed, holding (1) the trial judge's comments did not constitute a structural error, and (2) despite defense counsel's failure to object to the judge's improper remarks, Petitioner did not meet his burden of showing that the jury's verdict would reasonably likely have been different absent trial counsel's errors. View "Guthmiller v. Weber" on Justia Law

Kenneth Stark, a registered sex offender, was convicted of loitering in a community safety zone in violation of S.D. Codified Laws 22-24B-24. On appeal, the Supreme Court affirmed, holding (1) the state statutes prohibiting sex offenders from loitering in community safety zones are constitutional; (2) the trial court did not err by allowing the State to amend the information to include the correct location of Stark's prior felony conviction; (3) there was sufficient evidence to establish that Stark's primary purpose for remaining in the community safety zones was to observe or contact minors; and (4) the trial court did not abuse its discretion by admitting evidence that an individual in a white mini-van registered to Stark was seen in a community safety zone the day before the charged conduct occurred. View "State v. Stark" on Justia Law

Timothy Farmer, a patrol officer for the Rapid City Police Department, was investigated for excessive use of force relating to the apprehension of the alleged perpetrators of an assault. The Department later fired Farmer after finding, in addition to the most recent incident, Farmer had been the subject of several complaints for excessive force. The Department of Labor upheld the Police Department's decision. The circuit court affirmed, finding ample evidence to support the discharge. On appeal, Farmer contended that he never acted beyond the Department's use of force continuum policy. The Supreme Court affirmed the judgment of the Department of Labor and circuit court, holding that sufficient cause existed to discharge Farmer. View "Farmer v. City of Rapid City" on Justia Law

J.L. was fourteen when he engaged in consensual sexual intercourse with his twelve-year-old girlfriend. A juvenile petition was filed against J.L., and the circuit court adjudicated J.L. as a delinquent under S.D. Codified Laws 22-22-1(1), a statute under which the girlfriend was legally incapable of giving consent and under which J.L. would have been convicted of rape in the first degree had J.L. been an adult. On appeal, J.L. argued that the application of the statute to the facts of this case created an absurd result, one not reasonably intended by the legislature. The Supreme Court affirmed, holding that application of the statute to the facts did not suggest an unintended absurdity. View "In re J.L. " on Justia Law