Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the circuit court granting Defendant's motion to suppress statements he made to a state officer on the grounds that the officer lacked authority to investigate crimes in Indian country, holding that the officer did not violate any jurisdictional principles by entering Indian country to investigate crimes that occurred outside Indian country.When Defendant spoke with agents from the South Dakota Division of Criminal Investigation and the Bureau of Indian Affairs at his home located on Indian trust land concerning property crimes that had occurred outside Indian country he produced evidence implicating him a burglary in Bennett County. Defendant was charged in state court. The circuit court suppressed Defendant's statements, concluding that the agents did not have authority to investigate state criminal offenses in Indian country. The Supreme Court reversed, holding (1) Defendant failed to show that the agents lacked authority to investigate state offenses while in Indian country or that the agents' actions infringed upon tribal sovereignty; and (2) Defendant failed to show a Fourth Amendment violation. View "State v. Cummings" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court reversing and modifying the decision of the hearing examiner modifying the Roberts County Director of Equalization's tax assessments on four of James Pirmantgen's properties but affirming the County's remaining twelve assessments, holding that the circuit court erred.On appeal, the County argued that the circuit court erred in concluding that it failed properly to value Pirmantgen's properties for tax assessment purposes. The Supreme Court held (1) the circuit court properly determined that the hearing examiner's valuations as to three parcels were clearly erroneous; (2) the circuit court erred in reversing the hearing examiner's decision as to ten properties and in directing the County to reduce the assessments on these properties; and (3) because the circuit court did not have the authority to order a refund of taxes, it erred in directing the County to reimburse Pirmantgen any taxes paid in excess of what should have been paid. View "Pirmantgen v. Roberts County" on Justia Law

The Supreme Court affirmed the judgment of the circuit court entering judgment in favor of Rapid City Medical Center (RCMC) and three of its doctors (collectively, Defendants) in this negligence action, holding that the circuit court did not abuse its discretion by denying Plaintiff's request to call two rebuttal witnesses and refusing Plaintiff's proposed jury instruction on agency.In her complaint, Plaintiff alleged that Defendants did not inform her of a growing mass in her chest that caused persistent issues with her throat and chest until the mass was removed. The jury returned a verdict in favor of Defendants. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion when it denied Plaintiff's request to call two rebuttal witnesses in an attempt to lay foundation for medical records not offered during Plaintiff's case-in-chief; and (2) the circuit court did not abuse its discretion when it limited the agency instruction relative to the claims Plaintiff raised against Defendants. View "Frye-Byington v. Rapid City Medical Center" on Justia Law

The Supreme Court affirmed the decision of the trial court denying Defendant's motion for a new trial, holding that the trial court did not abuse its discretion by failing to remove a potential juror for cause.A jury found Defendant guilty of two counts of sexual contact with a child under sixteen. Defendant filed a motion for a new trial on the grounds of jury misconduct and irregularity, arguing that the trial court abused its discretion by denying the removal of a juror for cause. The trial court denied the motion. The Supreme Court affirmed after reviewing the entire void dire proceeding, holding that the trial court did not abuse its discretion in denying Defendant's motion to remove the juror at issue for cause. View "State v. Leader Charge" on Justia Law

The Supreme Court reversed Defendant's convictions of three counts of grand theft by misappropriation of funds by a contractor, holding that the circuit court erred by denying Defendant's motion for judgment of acquittal.Each count on which Defendant was convicted concerned a different construction project. On appeal, Defendant argued that the State presented insufficient evidence to support his convictions. The Supreme Court agreed and reversed the convictions, holding that the State failed to present sufficient evidence on one or more essential elements, and therefore, the circuit court erred in denying Defendant's motion for judgment of acquittal on each conviction. View "State v. Suchor" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentences for kidnapping, rape, aggravated assault, and commission of a felony with a firearm, holding that there was no error or abuse of discretion.Specifically, the Supreme Court held (1) the circuit court did not abuse its discretion when it granted the State's motion in limine regarding erotic asphyxiation; (2) Defendant's prosecutorial misconduct claims were unfounded; (3) the circuit court did not err in denying Defendant's motion for judgment of acquittal on all counts on which Defendant was convicted; and (4) Defendant's seventy-five-year sentence was not grossly disproportionate in violation of the Eighth Amendment. View "State v. Seidel" on Justia Law

The Supreme Court affirmed the judgment of the circuit court concluding that Plaintiffs had standing to bring this declaratory judgment action challenging ad valorem property taxes that Day County assessed against them and upholding the disputed taxes, holding that the circuit court did not err.Plaintiffs were the Pickerel Lake Outlet Association, a South Dakota domestic non-profit corporation, and forty non-Indian owners of permanent improvements around Pickerel Lake. Plaintiffs claimed that federal law preempted taxation because their structures were on land held in trust for the Sisseton-Wahpeton Oyate or its members. The State defended the County's authority to levy the taxes, arguing that preemption did not apply and challenging Plaintiffs' standing to sue. The circuit court concluded that Plaintiffs had standing and upheld the County's authority to assess the taxes. The Supreme Court affirmed, holding (1) Plaintiffs satisfied all the prerequisites for standing; and (2) the County was neither explicitly nor implicitly preempted by the provisions of 25 U.S.C. 5108 from assessing ad valorem taxes against Plaintiffs. View "Pickerel Lake Outlet Ass'n v. Day County" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated assault and two counts of simple assault for attacking his former significant other, Rosa Sosa, holding that the circuit court did not err in excluding evidence of Sosa's drug use and that Defendant was not entitled to relief on his double jeopardy claims.Specifically, the Supreme Court held (1) the circuit court did not err in granting the State's motion in limine to exclude evidence of the victim's methamphetamine use; and (2) Defendant's convictions for multiple counts of assault did not subject him to double jeopardy. View "State v. Babcock" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and other offenses, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Court held (1) if the circuit court erred in denying Defendant's motion to suppress his statements to law enforcement, the error was harmless because the statements were cumulative to other evidence received; (2) the circuit court did not abuse its discretion or commit prejudicial error by refusing to declare certain witnesses adverse; (3) Defendant's Sixth Amendment rights were not violated; and (4) the evidence presented at trial was sufficient to support Defendant's guilty verdict on all counts. View "State v. Quinones Rodriguez" on Justia Law

In this case brought by a patient who sued her doctor for lack of informed consent, the Supreme Court reversed the decision of the circuit court granting in part Plaintiff's motion to compel the production of medical records of Defendant's non-party patients, holding that the circuit court erred.Plaintiff underwent an anterior spinal surgery with Defendant, a general surgeon, to relieve lower back pain. After Defendant performed a vertical incision rather than Plaintiff's requested horizontal incision Plaintiff brought this action alleging that Defendant performed the vertical incision without Plaintiff's informed consent. At issue was Plaintiff's motion to compel certain non-party patients' medical records. The circuit court granted the motion to compel in part, limiting the scope of the discoverable records. The Supreme Court reversed the order, holding that the records Plaintiff requested were irrelevant and therefore not discoverable. View "Ferguson v. Thaemert" on Justia Law