Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's misdemeanor conviction for intentional damage to property following a court trial, holding that the circuit court erred by accepting the argument of the prosecutor that intentional damage to property is a strict liability offense for which a defendant who caused damage is necessarily guilty.Defendant was charged with intentional damage to property as a Class 1 misdemeanor for striking the windshield of a vehicle with her hand held in a fist, cracking it. During trial, Defendant argued that she could not be guilty because she did not intend to crack the windshield. The circuit court found Defendant guilty, aligning its rationale with the State's strict liability theory. The Supreme Court reversed, holding that intentional damage to property, as described S.D. Codified Laws 22-34-1, requires the State to prove that the Defendant acted with the specific intent to cause damage to the subject property. View "State v. Vandyke" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of first-degree rape and two counts of sexual contact with a child under the age of sixteen, holding that Defendant was not entitled to relief on his claims of error.After a jury trial, Defendant was found guilty of rape and sexual contact with a minor and sentenced to two consecutive sixty-year terms of imprisonment on the rape convictions. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Defendant's motion for judgment of acquittal on the two rape charges; (2) the submission of the sexual contact charges to the jury did not violate the prohibition against double jeopardy; (3) there was no improper bolstering of witnesses at trial by either the circuit court or the prosecution; (4) the circuit court did not abuse its discretion by denying Defendant's motion for a new trial; (5) Defendant's sentence neither violated the constitutional prohibition against cruel and unusual punishment, nor did it constitute an abuse of discretion; and (6) no other prejudicial error occurred. View "State v. Manning" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of nine counts of third-degree rape involving J.C., holding that Defendant was not entitled to relief on any of his allegations of error.During the trial, the circuit court rejected the legal basis of Defendant's defense theory that J.C. gave "advance consent" to to sexual penetration before she passed out and became incapable of of giving contemporaneous consent. The circuit court rejected the legal basis of the defense and consequently excluded evidence that J.C. gave advance consent. The Supreme Court affirmed on appeal, holding (1) there was no error in the circuit court's decision regarding the advance consent theory and the court's exclusion of the relevant evidence; (2) the circuit court did not err by failing to instruct the jury on a definition of intoxication; and (3) this Court declines to address Defendant's claim of ineffective assistance of counsel on direct review. View "State v. Malcolm" on Justia Law

The Supreme Court affirmed Defendant's conviction for attempted first-degree murder, four counts of aggravated assault, and commission of a felony while armed with a firearm, holding that there was no error in the proceedings below.After a jury trial, Defendant was convicted. After a habitual offender trial, the jury found that Defendant had five prior felony convictions and ordered him to serve twenty-five years for attempted first-degree murder. The Supreme Court affirmed, holding that applying the correct standard leads to the conclusion that sufficient evidence supported the circuit court's decision to deny Defendant's motions for judgment of acquittal. View "State v. At The Straight" on Justia Law

The Supreme Court affirmed Defendant's conviction of open container and driving under the influence (DUI) and imposing a suspended imposition of sentence, holding that the circuit court did not err in denying Defendant's motion to suppress.Based on information obtained during a 911 call made by Defendant's daughter reporting that Defendant may be drinking and driving and providing Defendant's location officers conducted a traffic stop of Defendant's van and then arrested her for DUI. Defendant filed a motion to suppress, arguing that the traffic stop was an unconstitutional search and seizure. The circuit court denied the motion and found Defendant guilty. The Supreme Court affirmed, holding that, under the totality of the circumstances, the circuit court properly concluded that law enforcement had reasonable suspicion to believe that Defendant was driving under the influence of alcohol at the time of the stop. View "State v. Rosa" on Justia Law

The Supreme Court affirmed Defendant's conviction of third-degree rape, entered following a jury trial, holding that there was sufficient evidence in the record to sustain the conviction, and therefore, the circuit court did not err in denying Defendant's motion for a judgment of acquittal.After a jury trial, Defendant was found guilty of third-degree rape and sentenced to ten years in prison with eight years suspended. On appeal, Defendant argued that the evidence did not prove beyond da reasonable doubt that actual penetration occurred, as required by S.D. Codified Laws 22-22-1(3). The Supreme Court affirmed, holding that there was sufficient evidence in the record to support the jury's verdict finding Defendant guilty of third-degree rape. View "State v. McDermott" on Justia Law

The Supreme Court affirmed Defendant's convictions of first-degree rape and sexual contact, holding that Defendant was not entitled to relief on any of his allegations of error.After a second trial, a jury found Defendant guilty of sexually assaulting two of his children and one of his children's friends and sentenced him to life imprisonment on each of the three counts of first-degree rape and fifteen years on the sexual contact count, all to run consecutively. The Supreme Court affirmed, holding that the circuit court (1) abused its discretion in excluding witness testimony offered in Defendant's case-in-chief, but the error was harmless beyond a reasonable doubt; (2) did not err in allowing the State to admit a trial transcript of Defendant's testimony from his first trial; (3) did not abuse its discretion in allowing the State to admit other act evidence and expert testimony; and (4) did not abuse its discretion in ordering Defendant to pay certain costs of prosecution. View "State v. Guzman" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree rape, in violation of S.D. Codified Laws 22-22-1(1), holding that the court did not err in denying Defendant's request to withdraw his guilty plea.Defendant pled guilty to sexual penetration of a victim less than thirteen years of age. After a change of plea hearing but prior to sentencing, Defendant unsuccessfully filed a letter asking the circuit court to withdraw his guilty plea and requesting substitute counsel. After denying both requests the court sentenced Defendant to 100 years in prison with fifteen years suspended. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in denying Defendant's request to withdraw his guilty plea; and (2) this Court declines to address Defendant's ineffective assistance of counsel claim on direct review. View "State v. Alvarez" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant, after a jury trial, of two counts of first-degree rape, holding that the circuit court did not abuse its discretion in the way it handled Defendant's arraignment or in its evidentiary rulings and that misconduct that occurred during the State's closing rebuttal argument did not constitute prejudicial error.On appeal, Defendant claimed that his arraignment violated his due process rights and S.D. Codified Laws 23A-7-1 and that the circuit court abused its discretion in several of its evidentiary rulings. The Supreme Court disagreed and affirmed, holding (1) the challenged evidentiary rulings were without error and were not an abuse of discretion; and (2) while the prosecutor committed misconduct during closing argument, it was improbable that the prosecutor's misconduct altered the jury's verdict. View "State v. Hankins" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for habeas corpus, holding that the circuit court did not err in denying the petition after holding an evidentiary hearing.Appellant was convicted of three counts of first-degree rape and one count of sexual contact with a child under sixteen for raping and having sexual contact with his four-year-old autistic daughter. The conviction was affirmed on appeal. Appellant later filed a petition for habeas corpus alleging several instances of ineffective assistance of counsel. After a hearing, the circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to establish that his trial counsel provided ineffective assistance. View "Spaniol v. Young" on Justia Law