Justia South Dakota Supreme Court Opinion Summaries

Mark Black was hired as an agent of the South Dakota Division of Criminal Investigation (DCI) in 2005. Approximately one decade later, DCI terminated Black’s employment after a series of incidents and disciplinary actions. The Civil Service Commission (CSC) found that DCI had just cause to terminate Black’s employment. The circuit court affirmed. The Supreme Court affirmed, holding (1) CSC did not err in finding that DCI had just cause to terminate Black’s employment; and (2) DCI complied with the applicable rules and regulations and afforded Black due process of law. View "Black v. Division of Criminal Investigation" on Justia Law

Defendant was charged with murder and kidnapping. Defendant was a juvenile at the time of the crime. The State moved to transfer Defendant’s case to adult court. After a hearing, the juvenile court granted the State’s motion to transfer. After a trial in adult court, the jury found Defendant guilty of first-degree murder (arson), first-degree felony murder, first-degree arson, felony murder (aggravated kidnapping), and second-degree aggravated kidnapping. Defendant was sentenced to eighty years imprisonment for the murder conviction and a concurrent fifty-year sentence for second-degree aggravated kidnapping. The Supreme Court affirmed, holding (1) the juvenile court did not err in transferring Defendant to adult court; (2) the circuit court did not fail to adequately instruct the jury on Defendant’s theory of defense; and (3) Defendant’s eighty-year-sentence was not an abuse of discretion, grossly disproportionate, or a de facto life sentence in violation of the spirit of Montgomery v. Louisiana. View "State v. Diaz" on Justia Law

Defendant was indicted for eight drug-related offenses. After a jury trial, Defendant was convicted of seven of the eight counts. Defendant appealed, arguing (1) the trial court erred by amending the indictment the day before trial, and (2) the trial court committed plain error by not informing the parties of a jury question that arose during deliberations and then by answering that question without input from the parties. The Supreme Court affirmed, holding (1) the trial court did not commit plain error by amending the indictment the day prior to trial; and (2) the trial court did not commit plain error by not notifying the parties of the jury’s question at the time it occurred. View "State v. Schrempp" on Justia Law

Defendant was arrested and charged with driving under the influence after police officers approached a parked vehicle and found Defendant in the driver’s seat and smelled the odor of alcohol. Defendant filed a motion to suppress, asserting that the officer did not have reasonable suspicion to support the intrusion. The circuit court denied the motion to suppress, holding that the officer’s investigation was justified under the community caretaker exception to the warrant requirement. The Supreme Court affirmed, holding that the circuit court did not err when it concluded that the community caretaker exception to the warrant requirement applied and thus denied Defendant’s motion to suppress. View "State v. Kleven" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated assault. Defendant was sentenced to twenty years in the state penitentiary. Defendant appealed, arguing that the trial court erred by allowing a nurse practitioner who helped care for the victim to give her opinion regarding the seriousness of the victim’s injuries. The Supreme Court affirmed, holding that the circuit court did not err, let alone commit plain error, in permitting the nurse practitioner to opine whether the victim suffered a serious bodily injury, and therefore, Defendant was not deprived of a fair trial by jury. View "State v. Greenwood" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The circuit court sentenced Defendant to life imprisonment without parole. Defendant appealed, challenging the circuit court’s denial of his motion to suppress. Specifically, Defendant argued that the court erred when it found that exceptions to the warrant requirement existed and erred by failing to suppress his statements made to law enforcement prior to receiving Miranda warnings. The Supreme Court affirmed, holding (1) exigent circumstances existed justifying the officers’ warrantless entry of Defendant’s apartment; and (2) the admission of Defendant’s statements that he made to law enforcement before he received Miranda warnings was proper. View "State v. Rogers" on Justia Law

Thomas Konrad and Myron Stoebner entered into a contract for the sale of real property. Under the contract, the Stoebners agreed to sell Konrad nine parcels of real estate. The contract contained an arbitration clause. When the Stoebners refused to close on the sale of Parcel 7, Konrad sent the Stoebners a demand for arbitration. The arbitrator ruled that the Stoebners breached the contract and ordered the Stoebners to transfer Parcel 7 to Konrad. The Stoebners moved to vacate the award, arguing that the arbitrator exceeded his powers by disregarding the contractual definition of “transfer.” The circuit court denied the Stoebners’ application and confirmed the arbitration award. The Supreme Court affirmed, holding that the circuit court did not err when it confirmed the arbitration award in favor of Konrad because the arbitrator did not exceed his powers when he decided the issue submitted. View "Konrad v. Stoebner" on Justia Law

Bonnie Jean Pease executed a holographic will approximately seven months before her death. The will disinherited Pease’s mother, sister, and brother but not her brother Douglas Hubert. At issue before the circuit court was whether Pease intended to devise anything to Lisa and Lynn Schock, who were named in the will as the executors of Pease’s estate and to whom Pease gave “all [her] belongings…” contingent on them giving a share to Hubert, to a search for a home for her bird, and to fund litigation against the State. The circuit court ruled that after the Schocks set aside the requested funds, they were to distribute the entire residual estate to Hubert. The Schocks appealed, arguing that the gifting language of the will gave them a conditional gift. The Supreme Court reversed, holding that the will gave Pease’s property to Schocks subject to the stated convictions. View "In re Estate of Hubert" on Justia Law

Plaintiffs filed lawsuits against Defendants - a medical doctor, his medical clinic, two hospitals, and other individual defendants (collectively, Defendants) - alleging various causes of action, including negligence, negligent credentialing, fraud, and deceit. Plaintiffs sought production of documents from Defendants, but Defendants declined to produce all of them, asserting that some of the materials sought were peer review materials protected under S.D. Codified Laws 36-4-26.1. Plaintiffs moved to compel production, asking the circuit court to determine that section 36-4-26.1 was unconstitutional. The circuit court ordered Defendants to produce, without in camera review, documents protected by peer review, determining that the statute was constitutional only if it applied a “crime-fraud exception” and that the exception had been met in this case. The Supreme Court reversed, holding that the circuit court erred (1) by creating a crime-fraud exception to section 36-4-26.1, and (2) by ordering Defendants to produce materials in the possession of medical peer review committees. View "Novotny v. Sossan" on Justia Law

In 2007, Appellant pleaded guilty to two counts of possession of child pornography and admitted that he was a habitual offender. Appellant did not directly appeal his conviction. Nearly seven years after his conviction became final, Appellant filed a petition for a writ of habeas corpus, alleging multiple claims of ineffective assistance of counsel and a Miranda violation. After a hearing, the habeas court concluded that Appellant’s habeas petition was untimely and granted the State’s motion for summary judgment, dismissing Appellant’s petition with prejudice. The Supreme Court reversed, holding (1) the habeas court did not err in applying S.D. Codified Laws 21-27-3.3 to Appellant’s action because Appellant commenced the action after the effective date of the statute; but (2) in applying section 21-27-3.3, the habeas court had the authority to delay commencement of the two-year limitations period until the effective date of the statute, and because Appellant filed the action within the two years, the habeas court erroneously granted summary judgment against Appellant for violating the statute of limitations in section 21-27-3.3. View "Hughbanks v. Dooley" on Justia Law