Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court imposing a penitentiary sentence after Defendant pleaded guilty to two felonies, holding that the State's comments at sentencing did not breach its implied obligation of good faith under the terms of the plea agreement.Pursuant to a plea agreement, Defendant pleaded guilty to one count of abuse or cruelty to a minor, in exchange for the State's recommendation for a suspended execution of sentence, and also pleaded guilty to one count of a controlled substance, in exchange for the State's recommendation of a fully suspended sentence. The circuit court accepted Defendant's guilty pleas and then sentenced her to twelve years' imprisonment with eight years suspended on the child abuse conviction. On appeal, Defendant argued that the State's sentencing argument violated the plea agreement. The Supreme Court affirmed, holding that Defendant's argument was insufficient to meet her burden under plain error review. View "State v. Guziak" on Justia Law

The Supreme Court affirmed the judgment of the circuit court terminating the parental rights of Father, holding that any error committed by the circuit court did not prejudice Father.After a hearing, the circuit court issued a decision terminating the parental rights of Mother and Father to their three children. Father appealed. The Supreme Court affirmed, holding that the circuit court (1) erred when it prematurely signed the State's proposed findings, but Father failed to establish prejudice caused by the error; (2) did not err when it determined that the Department of Social Services made active efforts to prevent the breakup of the family; (3) did not clearly err in finding that Father's continued custody of the children would result in serious physical or emotional harm; and (4) did not err when it found that termination of Father's parental rights was the least restrictive alternative commensurate with the best interests of the children. View "In re A.A." on Justia Law

The Supreme Court affirmed the circuit court's dismissal of this election contest and its determination that Constitutional Amendment A was submitted to the voters at the November 3, 2020 election in violation of the single subject requirement in S.D. Const. art. XXIII, 1, holding that the circuit court did not err.At the election at issue, South Dakota voters approved Amendment A, "An amendment to the South Dakota Constitution to legalize, regulate, and tax marijuana; and to require the Legislature to pass laws regarding hemp as well as laws ensuring access to marijuana for medical use." Plaintiffs filed a statutory election contest and a separate declaratory judgment action claiming Amendment A was unconstitutional. The circuit court dismissed the election contest, concluding it was not an appropriate proceeding to challenge the amendment, but concluded in the declaratory judgment action that Amendment A violated Articles XXIII, 1 and 2. The Supreme Court affirmed, holding (1) Plaintiffs identified no irregularity in the election process; and (2) the submission of Amendment A to the voters plainly and palpably violated Article XXIII, 1. View "Thom v. Barnett" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for assault by a jail inmate - contract with bodily fluids, simple assault against an inmate, and threatening a law enforcement officer, holding that there was no error or abuse of discretion.On appeal, Defendant argued that the circuit court abused its discretion by admitting a surveillance video into evidence and that the error prejudiced the outcome of his trial. Specifically, Defendant argued that a lay foundation was required under S.D. Codified Laws 19-19-901(b)(1) to authenticate the video and that that the necessary foundation was not laid in this case. The Supreme Court affirmed, holding that the evidence adequately supported the circuit court's finding that the video was an accurate recording of the incident leading to Defendant's convictions. View "State v. Reeves" on Justia Law

In this divorce action, the Supreme Court reversed the circuit court's valuation of the marital estate, inclusion of certain property in the marital estate, and determination that Kibbe Conti owed Russell Conti an $11,436 cash equalization payment, holding that the circuit court erred.This appeal concerned only the valuation and division of certain property. The Supreme Court reversed, holding (1) the circuit court's valuation of the marital residence was clearly erroneous; (2) on remand, the circuit court is further directed to apply the legal factors outlined in this opinion and enter findings specifically addressing why certain property should be considered marital or non marital; and (3) the circuit court's determination that Kibbe owed Russell an $11,436 cash equalization payment was based on clear error. View "Conti v. Conti" on Justia Law

The Supreme Court reversed the judgment of the circuit court committing seventeen-year-old D.S. to the custody of the Department of Corrections (DOC) pursuant to S.D. Codified Laws 26-8C-7 after adjudicating him of first-degree rape, holding that the court committed reversible error because its findings and conclusions were insufficient to permit meaningful review.In announcing its disposition, the circuit court did not address whether the recommendations before it for community supervision and outpatient treatment were viable alternatives to DOC custody or whether commitment to the DOC was the least restrictive alternative in D.S.'s best interest. The day after the deposition hearing, the court entered written findings of fact and conclusions of law stating simply that there were no other viable alternatives and that commitment to the DOC was the least restrictive alternative. The Supreme Court reversed, holding that remand was required for the circuit court to make findings on the viability of a community-based supervision and treatment alternative and to reimpose a disposition consistent with the requirements of section 26-8C-7. View "In re D.S." on Justia Law

The Supreme Court affirmed the decision of the circuit court order several search warrants involving the Implicated Individual in this case and corresponding inventories to be unsealed, holding that there was no error.A special agent of the South Dakota Division of Criminal Investigation sought several search warrants involving the Implicated Individual, and the circuit court approved the warrants. The warrants, along with the supporting affidavits and inventories, were filed with the clerk of courts. At the agent's request, the circuit court sealed the search warrants but ultimately ordered that the search warrants and corresponding inventories be unsealed. The Supreme Court affirmed, holding that S.D. Codified Laws 23A-35-4.1 prohibits a court from sealing a search warrant or the verified inventory. View "In re Matter of Implicated Individual" on Justia Law

The Supreme Court reversed the judgment of the circuit court issuing a permanent protection order against Matthew Batchelder, holding that the circuit court's order did not rest upon sufficient factual and legal support.While expressing its reluctance against the appropriateness of issuing a permanent protection order against Matthew, the court indicated that the protection order was necessary to ease the contentious relationship between Matthew and his former wife, Ame Batchelder. The court, however, did not issue any oral or written findings. The Supreme Court reversed, holding that the lack of findings and legal justification rendered the protection order infirm. View "Batchelder v. Batchelder" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder but reversed the court's restitution order in part, holding that the restitution order did not comply with S.D. Codified Laws 23A-28-3.After finding Defendant guilty of second-degree murder, the circuit court imposed a mandatory sentence of life imprisonment, costs of prosecution and restitution. On appeal, Defendant argued, among other things, that the court erred in fashioning its order of restitution requiring him to pay future counseling costs and other expenses incurred by the victim's family members. The Supreme Court affirmed Defendant's conviction but reversed in part the restitution order, holding (1) the circuit court did not err in denying Defendant's motion for judgment of acquittal; (2) the circuit court did not abuse its discretion in its evidentiary rulings; and (3) the restitution order imposed arbitrary caps without specifying timeframes or mechanisms by which specific amounts to be reimbursed to the victim's family could be ascertained. View "State v. Falkenberg" on Justia Law

The Supreme Court reversed the judgment of the circuit court declaring N.A. a delinquent child, holding that the circuit court erred by finding that Officer Brandon Bassett did not use excessive force against N.A.When responding to a possible drive-by shooting at N.A.'s family's apartment, Officer Bassett was told by N.A. that the messages she had sent her mother reporting the drive-by shooting were a prank. Officer Bassett, believing that N.A. was impeding the investigation, grabbed N.A., pulled her down onto a mattress on the floor and handcuffed her. N.A. kicked Officer Bassett during the altercation. The State subsequently brought this petition alleging that because she assaulted a law enforcement officer, N.A. was a delinquent child. The circuit court declared N.A. to be a delinquent child. The Supreme Court reversed, holding that Officer Bassett used excessive force to detain N.A. and, on remand, the circuit court should complete the analysis of N.A.'s self-defense claim. View "Interest Of N.A." on Justia Law