Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court vacated Defendant's sentence imposed in connection with his guilty plea to first-degree manslaughter, holding that the district court abused its discretion in imposing the sentence.After a confrontation with Lucas Smith at a local bar, Defendant, who was carrying a handgun, encountered Smith in a nearby alley. Smith ran toward Defendant, yelling for Defendant to shoot him. Defendant took a few steps back and then fatally shot Smith. Defendant pled guilty to first-degree manslaughter under the theory that he was "resisting an attempt by [Smith] to commit a crime." The circuit court ultimately convicted Defendant to 124 years in the penitentiary. The Supreme Court vacated the sentence, holding (1) the circuit court overlooked the element of S.D. Codified Laws 22-16-15(4) that contemplates criminal conduct by Smith, which provided partial justification for Defendant's response; and (2) the court's decision to treat Defendant as solely responsible without regard for Smith's conduct was not harmless. View "State v. Mitchell" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court denying both parties' summary judgment motions as to Plaintiff's 42 U.S.C. 1983 claims, holding that the circuit court erred in denying summary judgment in favor of the City of Sioux Falls.Plaintiff brought this action against certain officers of the Sioux Falls Police Department and the City of Sioux Falls. The police officers and the City filed a motion for summary judgment. The circuit court (1) concluded that the officers were not entitled to qualified immunity; (2) denied summary judgment on Plaintiff's claim against the City due to material issues of fact. The Supreme Court held that the circuit court (1) erred in denying summary judgment on Plaintiff's claim that the officers' warrantless entry into her apartment violated her constitutional right to be free from unreasonable searches and seizures; (2) erred in denying the City's motion for summary judgment; and (3) properly concluded that material issues of fact were in dispute on the question of whether the officers used excessive force such that Defendants were not entitled to qualified immunity as a matter of law on this section 1983 claim. View "Boggs v. Pearson" on Justia Law

The Supreme Court affirmed the decision of the circuit court dismissing Appellants' creditor claim against the estate of John Calvin, holding that the circuit court properly dismissed the creditor claim.Calvin was the lifetime beneficiary of the Ben W. Calvin Trust, and Appellants - Calvin's children - were the remainder beneficiaries. After Calvin died, Appellants brought a creditor claim against his estate, alleging that Calvin had received disbursements of principal from the Trust in violation of the terms of the Trust. The circuit court dismissed the creditor claim, concluding that the Trust disbursements to Calvin were proper under the terms of the Trust. The Supreme Court affirmed, holding that Appellants failed to show that they had standing to assert a claim against the Estate. View "In re Estate Of Calvin" on Justia Law

The Supreme Court affirmed the final dispositional order of the circuit court terminating the parental rights of Mother and Father, the biological parents of C.R.W., holding that the circuit court did not err or abuse its discretion.C.R.W. was the subject of an abuse and neglect proceeding before the circuit court. C.R.W. was considered an Indian child under the Indian Child Welfare Act pursuant to 25 U.S.C. 1903(4), and the Oglala Sioux Tribe intervened in the proceeding. The Tribe moved to disqualify C.R.W.'s attorney on the grounds that the attorney had a conflict of interest with C.R.W. The circuit court denied the motion. During the proceedings, Mother and the Tribe moved to transfer the case to tribal court, but the motion was denied. After the parents' parental rights were terminated, Mother and the Tribe appealed. The Supreme Court affirmed, holding that the circuit court (1) did not err when it denied the Tribe's motions to disqualify C.R.W.'s attorney; and (2) did not abuse its discretion in denying Mother's motions to transfer jurisdiction. View "In re C.R.W." on Justia Law

The Supreme Court affirmed Defendant's conviction of driving a vehicle with alcohol in the blood in violation of S.D. Codified Laws 32-23-1(1), holding that the magistrate court's finding that Defendant provided valid, voluntary consent to the blood draw was not clearly erroneous.After law enforcement officers arrested Defendant for driving under the influence one of the officers asked Defendant if he would consent to a blood draw. Defendant twice answered, "okay," and his blood was drawn without a warrant. Defendant filed a motion to suppress, arguing that the blood draw was taken without a warrant or his valid consent. The magistrate court denied the motion. The circuit court affirmed. The Supreme Court affirmed, holding that the circuit court (1) applied the correct standard of review to the magistrate court's decision; and (2) did not err in affirming the magistrate court's decision that Defendant provided valid, voluntary consent to the blood draw. View "State v. Slepikas" on Justia Law

The Supreme Court reversed the judgment of the circuit court granting partial summary judgment in favor of Smith Angus Ranch Inc. (SAR) on its claims for breach of fiduciary duty and self-dealing, holding that the circuit court erred by excluding extrinsic oral evidence in this case.In its complaint, SAR alleged that Travis Hurst, while serving as a director and officer of SAR, wrongfully acquired SAR assets and made improper purchases using SAR funds. After the court prohibited Hurst from presenting extrinsic oral evidence to show he was authorized to carry out the contested transactions, SAR moved for partial summary judgment on its claims for breach of fiduciary duty and self-dealing. The court granted partial summary judgment for SAR. The Supreme Court affirmed, holding (1) the circuit court erred by excluding extrinsic oral evidence; and (2) questions of fact existed precluding summary judgment. View "Smith Angus Ranch v. Hurst" on Justia Law

The Supreme Court reversed the circuit court's dispositional order terminating Mother's rights to her daughter, holding that the evidence did not establish that active efforts were made to reunify Mother and the child.After a hearing, the court determined beyond a reasonable doubt that the State "made reasonable and active efforts to provide remedial services designed to prevent the breakup of the family and those rehabilitative programs [had] been unsuccessful." On appeal, Mother challenged the court's conclusion that active efforts were provided to prevent the breakup of the family and that the efforts were unsuccessful. The Supreme Court reversed, holding that the circuit court erred in terminating Mother's parental rights on the basis that the South Dakota Department of Social Services had been making active efforts since the inception of the case and that such efforts were unsuccessful. View "In re C.H." on Justia Law

The Supreme Court reversed the circuit court's adjudication of I.T.B. as a delinquent child, holding that the evidence in the record was insufficient to support a determination that I.T.B. had made a terroristic threat.The circuit court adjudicated I.T.B. a delinquent child for making a terrorist threat in violation of S.D. Codified Laws 22-8-13(1). The adjudication was based on I.T.B.'s conduct at a high school principal's office. Specifically, I.T.B. uttered the word "bomb" in earshot of other students and also picked up some scissors and uttered the words "kill someone." The Supreme Court reversed the adjudication, holding that I.T.B.'s utterances, without further context, were insufficient to support a determination beyond a reasonable doubt that I.T.B. threatened to commit a "crime of violence" or an "act dangerous to human life involving...any explosive device" with the intent to intimidate or coerce a civilian population, as required by section 22-8-13(1). View "In re Interest Of I.T.B." on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of second-degree and first-degree manslaughter and sentencing Defendant to life in prison on the murder conviction, holding that that the circuit court erred in one of its evidentiary rulings, but the error did not rise to the level of prejudicial error requiring reversal.On appeal, Defendant argued, among other things, that the circuit court's evidentiary rulings regarding the testimony of a particular witness and her subsequent impeachment were erroneous. The Supreme Court affirmed, holding that the circuit court (1) failed correctly to weigh the prejudicial effect of Defendant's statements made to the witness, but the error did not require reversal because it did not rise to the level of prejudicial error; (2) did not violate Defendant's right to be brought to trial within 180 days under S.D. Codified Laws 23A-44-5.1; and (3) did not err by denying Defendant's motions for judgment of acquittal. View "State v. Little Long" on Justia Law

The Supreme Court affirmed Defendant's conviction of possession of a controlled substance and several misdemeanor offenses, holding that the circuit court did not err by denying Defendant's motion to dismiss for a violation of the 180-day speedy trial rule.At issue on appeal was the circuit court's decision to exclude 102 days between the time of Defendant's first appearance and the trial in which a Minnehaha County warrant was outstanding. The Supreme Court affirmed, holding (1) the circuit court properly determined that the delay caused by Defendant's absence from Minnehaha County was attributable to him; and (2) therefore, the circuit court properly excluded the 102 days in which the Minnehaha County warrant was outstanding. View "State v. Langen" on Justia Law