Justia South Dakota Supreme Court Opinion Summaries

In 2012, a grand jury indicted Defendant for a DUI offense and for obstructing a public officer. A Part II Information was subsequently filed alleging that Defendant had been convicted of two prior DUI offenses. Defendant moved to dismiss the 2012 Part II Information, arguing that the prior convictions were invalid for enhancement purposes because the magistrate judges’ failure to strictly follow procedure resulted in the magistrate courts’ failure to obtain subject matter jurisdiction over the actions. The circuit court denied the motion. In 2013, Defendant pleaded guilty to driving or control of a motor vehicle while having .08 percent or more by weight of alcohol in his blood, as charged in the 2012 indictment. The circuit court denied Defendant’s request to be granted a suspended imposition of sentence, ruling that he was ineligible pursuant to S.D. Codified Laws 23A-27-13. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Defendant’s motion to dismiss the Part II Information because the courts in Defendant’s predicate convictions assumed proper jurisdiction over the cases; and (2) the circuit court’s application of section 23A-27-13 did not violate the constitutional prohibition against ex post facto legislation. View "State v. Smith" on Justia Law

After a jury trial, Defendant was convicted of first-degree burglary and obstructing a law enforcement officer. The Supreme Court affirmed, holding (1) obstructing law enforcement is an appropriate predicate offense to support a charge of first-degree burglary; (2) the trial court did not err by allowing the State to exercise a peremptory strike, where Defendant failed to prove that the State’s use of its peremptory strike was racially motivated; and (3) the trial court did not abuse its discretion by excluding a letter written by Defendant to the victims of the burglary as hearsay evidence. View "State v. Hatchett" on Justia Law

Shannon Flowers filed an application for writ of habeas corpus, which the trial court denied. More than thirty days after the circuit court’s denial, Flowers filed a motion for issuance of certificate of probable cause. In spite of the untimeliness of his motion, the circuit court granted Flowers’s motion and certified an issue for appeal. The Supreme Court dismissed Flowers’s appeal, holding (1) Flowers’s motion for issuance of certificate of probable cause was late, and therefore, jurisdictionally defective; and (2) because the circuit court lacked jurisdiction, the Court also lacked jurisdiction to consider the issue certified on appeal. View "Flowers v. Weber" on Justia Law

Dora Gaaskjolen was an eighty-seven year-old widow who suffered from a traumatic head injury and other physical ailments. Dora’s grandson, Shane, an attorney, filed a petition for appointment of temporary conservator, and the circuit court ordered Dacotah Bank to be Dora’s temporary conservator. Shane subsequently moved for Dacotah to be Dora’s permanent conservator, but Dora moved to set aside the appointment of Dacotah as temporary conservator and, instead, nominated her daughter Audrey to be her conservator. Ultimately, the circuit court granted Shane’s motion for Dacotah to be Dora’s permanent conservator and denied Dora’s motion, finding that it was in the best interests of Dora that Dacotah be appointed as her conservator. The Supreme Court affirmed, holding that the circuit court’s finding and conservator appointment had support in the record. View "In re Conservatorship of Gaaskjolen" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to simple assault under S.D. Codified Laws 22-18-1(4). The caption of the information included the words “domestic abuse,” but Defendant did not challenge whether the assault involved domestic abuse. Additionally, Defendant’s attorney acknowledged that Defendant was pleading guilty to simple assault (domestic abuse). Defendant moved to withdraw his guilty plea, arguing that the charging information was insufficient and that he did not knowingly and voluntarily plead guilty to simple assault (domestic abuse). The magistrate court denied the motion. The circuit court affirmed. The Supreme Court affirmed, holding (1) any argument Defendant had regarding defects in the information was waived because it was not raised prior to Defendant’s guilty plea; and (2) Defendant understood his rights, and his plea was knowing and voluntary. View "State v. Outka" on Justia Law

At issue in this appeal was a continuing dispute between Appellants, David and Connie Finneman and Rock Creek Farms Partnership (RCF), and Ann Arnoldy concerning the ownership of 16,700 acres of farmland. After a series of lawsuits, appeals, and various filings, the circuit court granted Arnoldy equitable ownership of the real estate outlined in two contracts for deed. The Supreme Court affirmed, holding, primarily, that the circuit court did not err in granting Arnoldy equitable ownership of the real estate in the contracts for deed and the right to cure the contracts for deed default under S.D. Codified Laws 21-50-3. View "L&L P’ship v. Rock Creek Farms" on Justia Law

Appellant submitted an application for a writ of mandamus asking the circuit court to compel Secretary of State Jason Gant to investigate the nominating petitions for Republic candidate Brian Gosh for the November 2012 election in Pennington County. The court dismissed Appellant’s application for failure to state a claim for which relief could be granted. Intervenors to the case moved to award attorney’s fees and to tax costs and disbursements against Appellant. Appellant, in the meantime, appealed the dismissal of her application. Subsequently, after a hearing, the circuit court granted the Intervenors’ motion. The Supreme Court affirmed the circuit court’s order, holding (1) the circuit court did not err in awarding the Intervenors attorney's fees after the hearing; (2) the court did not err when it held a hearing on the Intervenors’ motion for attorney’s fees and expenses while Appellant’s appeal on the underlying judgment on the merits was pending before the Court; and (3) Appellant was not entitled to relief on the Intervenors’ motion for attorney’s fees because Appellant failed to assert her issue with the circuit court when given the opportunity to do so. View "Strong v. Gant" on Justia Law

A federal court issued an arrest warrant for Christopher Yellow Eagle, whose warrant was referred to a task force that included federal and county law enforcement officers. The task force officers learned Yellow Eagle was living with Defendant, who had an outstanding warrant for her arrest. The task force arrested Defendant and Yellow Eagle at Defendant’s home after observing that Defendant and Yellow Eagle appeared to be under the influence of a controlled substance and had drugs on their persons. After a court trial, Defendant was convicted of possession of a controlled substance and sentenced to four years incarceration with four years suspended. Defendant appealed the circuit court’s denial of her motion to suppress, arguing (1) the task force officers who executed the arrest warrant were not authorized to enter her home to arrest her, and (2) because Yellow Eagle was a third party in her home, the officers were required to obtain a separate search warrant for the home. The Supreme Court affirmed, holding that the task force officers constitutionally entered Defendant’s home to arrest Defendant, or alternatively, Yellow Eagle. View "State v. Quevedo" on Justia Law

After a jury trial, Defendant was found guilty of eight counts of making false or fraudulent sales tax returns. On appeal, Defendant argued that the circuit court erred in (1) denying his Batson challenges to three peremptory strikes exercised by the State because the court’s Batson analysis was incomplete; and (2) denying his motion for judgment of acquittal. The Supreme Court (1) held that because the Court was unable to determine under the record the circuit court’s reason for denying the Batson challenges, limited remand was required to allow the circuit court to engage in the missing analysis; and (2) affirmed the denial of Defendant’s motion for judgment of acquittal, as the evidence was sufficient to sustain the convictions. View "State v. Guthmiller" on Justia Law

Plaintiff sued Defendant for specific performance of Plaintiff’s option to purchase a ranch owned by Defendant. Defendant counterclaimed, alleging that Plaintiff owed him rent. After a trial, the circuit court (1) denied Plaintiff’s request for specific performance, concluding that Plaintiff had not performed all the conditions precedent on his part; and (2) concluded that the parties had an implied or express contract requiring Plaintiff to pay Defendant rent. The Supreme Court (1) held that the circuit court did not clearly err in finding Plaintiff was the party who was materially at fault for the failure of the conditions and in therefore denying specific performance, but because the record did not reflect that the court considered whether specific performance was appropriate under the exception set forth in S.D. Codified Laws 21-9-5, the case was remanded for reconsideration of specific performance under this exception; and (2) the circuit court erred in concluding that either an express or an implied contract required Plaintiff to pay rent. View "Humble v. Wyant" on Justia Law