Justia South Dakota Supreme Court Opinion Summaries

The Supreme Court reversed the circuit court’s imposition of a three-year protection order barring Gregory Begnaud from all contact with his two minor children, concluding that the order was not statutorily authorized because (1) the petition filed by the children’s mother failed to meet the requirements of S.D. Codified Laws 25-10-3; and (2) the circuit court failed to find that the children were victims of domestic abuse as required under S.D. Codified Laws 25-10-5, and even if the court had made such a finding, it would have been unsupported by the record. Further, the Court held that the order was overbroad and an abuse of discretion. View "Purcell v. Begnaud" on Justia Law

Raymond Bennett, who was intoxicated and driving his motorcycle, entered a curve at a high rate of speed and drove into a ditch. He was killed in the accident. Several Highway Patrol troopers soon arrived to manage the scene and investigate the incident. Approximately an hour and a half later, Douglas Howard rounded the same curve and encountered a motorhome that was stopped in his lane of travel. Howard lost control of his motorcycle and was injured. Howard sued Bennett’s estate, alleging that Bennett’s negligence in his own accident proximately caused Howard’s injuries in the subsequent accident. The Estate moved for summary judgment. The circuit court denied the motion. The Supreme Court reversed, holding that Bennett’s negligence was not the proximate cause of Howard’s injuries as a matter of law. Remanded with instructions for entry of summary judgment in favor of the Estate. View "Howard v. Bennett" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and kidnapping. Defendant received concurrent, mandatory life sentences for the convictions. Defendant was fourteen years old when he committed the offenses. After the United States Supreme Court issued its decision in Miller v. Alabama, Defendant filed a motion in circuit court to correct an illegal sentence. The circuit court granted the motion. Following a resentencing hearing, the sentencing court resentenced Defendant to concurrent, 200-year sentences for first-degree murder and kidnapping. The Supreme Court affirmed, holding (1) Defendant failed to establish that his sentence is cruel and unusual in violation of the Eighth Amendment; and (2) the sentencing court did not abuse its discretion when it imposed concurrent, 200-year sentences. View "State v. Jensen" on Justia Law

In 2009, Defendant was convicted of aggravated criminal sexual abuse in Illinois. After he moved to South Dakota, Defendant was indicted on two charges of violating S.D. Codified Laws 22-24B-12, which requires registered sex offenders to inform law enforcement of their new addresses within three business days of moving. Defendant’s registration violations subjected him to an enhanced sentence as a repeat-registration violator, but the State did not seek enhancement under S.D. Codified Laws 22-24B-12.1. Instead, the State filed a part II information on both charges alleging that Defendant was a habitual offender under S.D. Codified Laws 22-7-7 because of Defendant’s 2009 felony conviction in Illinois. Defendant pleaded guilty to the failure-to-register charges in both indictments. After a court trial on the part II informations, the circuit court imposed class 5 felony sentences. The Supreme Court affirmed, holding (1) section 22-24-B-12.1 does not preempt the use of section 22-7-7; and (2) the circuit court did not err in refusing to dismiss the part II informations. View "State v. Clark" on Justia Law

After a court trial, Defendant was found guilty of driving with a .08 percent blood alcohol content. Defendant also pleaded guilty to a part II information alleging that this was his second driving under the influence offense. Defendant appealed the denial of his motion to suppress statements that he made to law enforcement that he had been drinking and driving, asserting that the statements were made in violation of his Miranda rights. The Supreme Court affirmed, holding that the totality of the circumstances surrounding the encounter between Defendant and the law enforcement officer did not amount to a custodial interrogation, and therefore, the circuit court did not err by denying Defendant’s motion to suppress any incriminating statements made during the encounter. View "State v. Hopkins" on Justia Law

Defendant pleaded guilty to sexual contact with a child under the age of sixteen. The circuit court sentenced Defendant to the mandatory minimum sentence of ten years’ imprisonment. Defendant appealed, asking that the Supreme Court remand for resentencing on the grounds that the mandatory minimum sentence under S.D. Codified Laws 22-22-1.2 allows the court to suspend part of the sentence to give him a probationary sentence. The Supreme Court affirmed, holding that the minimum sentence in section 22-22-1.2 does not allow for a term of probation rather than incarceration because the term “minimum sentences” in section 22-22-1.2 refers to required prison terms. View "State v. Bingham" on Justia Law

In this appeal from the settlement of the estate of Fred Finch, Dean Anderson, a beneficiary, challenged the award of expenses, disbursements, and attorney’s fees to the personal representative, Coral Headrick. Specifically, Anderson argued (1) the circuit court erred when it granted allowed Headrick to retain $13,355.42 in fees as personal representative because Headrick engaged in self-dealing while acting as Finch’s fiduciary, and (2) the circuit court erred when it allowed Headrick to recover partial attorney’s fees for the estate’s attorney because the fees allowed were, in fact, fees incurred for the attorney’s work in defending Headrick’s improper self-dealing. The Supreme Court affirmed, holding (1) the court properly found that Headrick was entitled to reasonable fees incurred for her time spent on the estate not relative to self-dealing; and (2) the court did not abuse its discretion in granting Headrick’s request to recover attorney’s fees from the estate for the work the estate’s attorney performed on behalf of the estate. View "In re Estate of Finch" on Justia Law

Twin brothers Ryan Alan Krause and Brian Michael Krause pleaded guilty to separate complaints alleging grand theft and four counts of unlawfully using a computer. The circuit court sentenced each of the Krauses to four years imprisonment for grand theft and two years imprisonment for each count of unlawfully using a computer system, and ordered all sentences to run consecutively. The Supreme Court affirmed, holding (1) the Krauses’ consecutive sentences for unlawfully using a computer system do not violate the Eighth Amendment’s prohibition against cruel and unusual punishment; and (2) the circuit court did not err by imposing sentences of imprisonment instead of probation for the unlawful-use-of-computer-system convictions. View "State v. Krause" on Justia Law

Defendant was convicted of driving under the influence. Defendant appealed, arguing that the trial court erred in denying his motion to suppress evidence resulting from a traffic stop, including the results of a blood test, arguing that the arresting officer lacked reasonable suspicion to conclude that Defendant had committed a crime in order to justify the traffic stop. The Supreme Court reversed, holding that the circuit court erred in denying Defendant’s motion to suppress because the arresting officer did not have a reasonable suspicion of criminal activity, and any evidence resulting from the stop was the product of an illegal search. View "State v. Stanage" on Justia Law

Defendant was convicted of first-degree murder and received a mandatory sentence of life in prison. Defendant was fourteen years old when he committed the offense. After the United States Supreme Court issued Miller v. Alabama, which barred mandatory life sentences against juvenile homicide offenders, Defendant filed a motion to have his sentence correct. After a hearing, the sentencing court resentenced Defendant to ninety-two years in prison. The Supreme Court affirmed, holding (1) a ninety-two-year sentence is not categorically unconstitutional for a fourteen-year-old child; (2) because Defendant had the opportunity for release at age sixty, his sentence was not the legal equivalent of a life sentence without parole; (3) the sentencing court properly considered the mitigating qualities of youth set forth in Miller; (4) Defendant’s sentence was not grossly disproportionate to the gravity of the offense; and (5) the sentencing court did not commit prejudicial error when it permitted an oral victim-impact statement by an individual outside the statutory definition of a victim. View "State v. Charles" on Justia Law