Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the habeas court denying Petitioner’s petition for a writ of habeas corpus arguing that his trial counsel’s assistance was ineffective in regard to his decision to plead guilty and in regard to sentencing.Pursuant to a plea agreement, Petitioner pleaded guilty to second-degree robbery. Petitioner did not file an appeal or file a motion to modify his sentence. Instead, he filed a petition for a writ of habeas corpus asking the circuit court to vacate his sentence. The habeas court denied the petition. The Supreme Court affirmed, holding that Petitioner failed to prove that the alleged errors in his trial attorney’s performance “actually had an adverse effect on the defense” under Strickland v. Washington, 466 U.S. at 693 (1984), and therefore, Petitioner was not entitled to relief. View "Madetzke v. Dooley" on Justia Law

The Supreme Court affirmed Appellant’s separate convictions and sentences for aggravated assault and escape. The Court held (1) the circuit court did not err in denying Appellant’s motion to suppress; (2) the circuit court did not err when it denied Appellant a new trial after the jury found him guilty of aggravated assault and guilty of the lesser-included offense of simple assault because the circuit court vacated the jury’s guilty verdict for simple assault; (3) the circuit court did not err when it denied Appellant’s motion for a judgment of acquittal; and (4) the circuit court did not abuse its discretion in certain evidentiary rulings. View "State v. Abdo" on Justia Law

The Supreme Court dismissed Appellant’s appeal from a circuit court’s order revoking the clerk of court’s issuance of letters of appointment and the clerk’s statement of informal probate and appointment of personal representative, holding that the circuit court’s order was not a final order from which an appeal can be taken.On appeal, Appellant argued that the circuit court erred in its revocation without giving Appellant notice or an opportunity to be heard. The Supreme Court held that, until further proceedings determined the rights of the parties as it related to the appointment of a personal representative and to the probate of the decedent’s will, the Court did not have appellate jurisdiction under S.D. Codified Laws 15-26A-3(2). View "Estate of Stanton W. Fox" on Justia Law

In this divorce action, the Supreme Court affirmed the circuit court’s valuation of a bank account on a date other than the date of divorce, the decision to recapture into the marital estate the value of home improvements made to a third party’s rental property, and the valuation of Husband’s three business interests. The Court held that the circuit court did not abuse its discretion when it (1) included the value of the bank account from eleven months before trial; (2) included $15,000 of improvements made to Husband's father’s rental property; and (3) valued Husband's business interests. View "Giesen v. Giesen" on Justia Law

The Supreme Court affirmed the judgment of the habeas court denying Appellant’s petition for a writ of habeas corpus. After a jury trial, Appellant was convicted of second-degree murder and aggravated assault. In his habeas petition, Appellant argued that the circuit court committed errors during the jury selection process that warranted a new trial and that his counsel provided constitutionally ineffective assistance. The habeas court concluded (1) the circuit court committed errors during the jury selection process, but the errors were not structural and Appellant did not prove prejudice; and (2) Appellant failed to prove that counsel was ineffective during the jury selection process. The Supreme Court affirmed, holding (1) the circuit court’s errors during the jury selection process were not structural and were harmless; and (2) Appellant failed to show that he receive ineffective assistance of counsel. View "Miller v. Young" on Justia Law

The Supreme Court affirmed the the circuit court’s classification and division of property in this divorce case in all but one respect as regards a clerical issue, which the Court remanded for clarification.Husband and Wife held most of their assets separately throughout their eighteen-year marriage. In granting them a divorce, the circuit court classified most of their assets as marital property and divided them equally. The Supreme Court held (1) the circuit court did not abuse its discretion in classifying the parties’ separately held assets as marital property; and (2) Wife was not entitled to relief on her arguments relating to the circuit court’s division and valuation of property with the exception of her argument that the circuit court erred in failing to divide and allocate three liabilities. Because the court’s failure to allocate these debts may have been a clerical error, the Supreme Court remanded the issue for the circuit court’s classification. View "Arendt v. Chamberlain" on Justia Law

The Supreme Court affirmed the order of the circuit court ordering Eryn Winegeart to sell real estate she owned jointly with her former spouse, Weston Winegeart, holding that the court did not err by ordering Eryn to sign a purchase agreement signed by a third party.After the parties underwent mediation, Weston signed an agreement with a real-estate agent to list the jointly owned real estate, and the listing agreement included a commission for the realtor. After the third party signed the purchase agreement, Eryn refused to sign it, asserting that during mediation Weston had orally agreed to sell the property without paying for a realtor. The circuit court found that the parties had not entered into an enforceable oral agreement in regard to realtor fees and ordered Eryn to sign the purchase agreement. The Supreme Court affirmed, holding that the circuit court did not err by entering its order requiring Eryn to sign the purchase agreement. View "Winegeart v. Winegeart" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of second-degree murder. The Court held that the circuit court did not err in (1) failing to dismiss the indictment on the ground that Defendant was not given notice of the coroner’s release of the body because Defendant failed to demonstrate prejudice; (2) denying Defendant’s motion for judgment of acquittal because the evidence was sufficient to support the verdict; and (3) admitting autopsy photographs into evidence because Defendant failed to show that the evidence was unduly prejudicial. View "State v. Quist" on Justia Law

The Supreme Court affirmed the circuit court’s partial denial of Plaintiffs’ partial denial of their request for preliminary injunctive relief against Defendant, their former agent, holding that the circuit court did not err by enjoining Defendant only from soliciting business from Plaintiffs’ existing customers without also enjoining Defendant from selling to those customers.Plaintiffs, Farm Bureau Life Insurance Co. and Farm Bureau Property and Casualty Insurance Co., argued in their complaint that Defendant, after leaving Farm Bureau, breached the agency contracts he entered into with Farm Bureau by selling insurance policies to clients to whom he had previously sold Farm Bureau policies. In partially denying Plaintiffs’ request for injunctive relief, the circuit court concluded that portions of the agency contracts that prohibited Defendant from selling to Farm Bureau’s existing customers was an invalid restraint on trade under S.D. Codified Laws chapter 53-9. The Supreme Court affirmed, holding that the plain meaning of section 53-9-12 supported the circuit court’s decision to adhere to that statute’s language. View "Farm Bureau Life Insurance Co. v. Dolly" on Justia Law

The Supreme Court reversed the judgment of the circuit court granting Defendant’s motion to suppress evidence found in the vehicle Defendant was driving, holding that, contrary to the circuit court’s finding, Defendant’s traffic stop was not unlawfully extended.Defendant was indicted on four felony drug charges after controlled substances were found in the vehicle she was driving. The circuit court granted Defendant’s motion to suppress, determining that the officer that stopped the vehicle unlawfully prolonged the traffic stop to question Defendant, conduct standard field sobriety tests, and call for a drug dog without reasonable suspicion of drug activity. The Supreme Court reversed, holding that the officer’s decision to extend the initial traffic stop to question Defendant about drug activity and to conduct the drug dog sniff was supported by reasonable suspicion, and therefore, the traffic stop was not unlawfully extended. View "State v. Barry" on Justia Law