Justia South Dakota Supreme Court Opinion Summaries

Plaintiff filed for and obtained an ex parte temporary protection order against Defendant, a former social acquaintance. The Supreme Court affirmed, holding (1) the circuit court’s findings of fact were not clearly erroneous; (2) the circuit court did not abuse its discretion in granting the protection order; (3) Defendant received the notice that due process requires; (4) the circuit court did not abuse its discretion in permitting “other acts” evidence; (5) S.D. Codified Laws 22-19A-1, as applied in this case, was not unconstitutionally vague; and (6) the circuit court did not abuse its discretion in crafting the protection order. View "Donat v. Johnson" on Justia Law

As part of a plea agreement, Defendant pleaded guilty to possession of methamphetamine. After a sentencing hearing, the district court sentenced Defendant to five years in the penitentiary. The Supreme Court affirmed, holding (1) the totality of the circumstances established that Defendant entered his guilty plea voluntarily, knowingly, and intelligently; and (2) Defendant’s constitutional rights were not violated when the circuit court sentenced him to the maximum sentence of five years imprisonment, as the sentence was not grossly disproportionate to the offense committed. View "State v. Moran" on Justia Law

After a jury trial, Defendant was convicted of first-degree rape and sexual contact involving a child. During the trial, the trial judge, on his own initiative, and without a preclosure hearing, closed the courtroom during the victim’s testimony. The jury found Defendant guilty of both charges. After trial, the State moved to supplement the record with facts and reasons for the closure. Defendant moved for a new trial based on the closure. The circuit court granted the State’s motion and denied Defendant’s motion for a new trial. Following a hearing, the court entered findings of fact and conclusions of law supporting closure. The Supreme Court affirmed, holding (1) the circuit court’s error in not having a preclosure hearing to determine whether closure was justified did not require a new trial; and (2) the circuit court made adequate findings demonstrating an overriding interest that was no broader than necessary, considering the alternatives, for courtroom closure during the victim’s testimony. View "State v. Slota" on Justia Law

Before he died, the Decedent transferred two quarter sections of Indian trust land located in Tripp County, South Dakota, to his son. The Decedent’s estate (the Estate) filed this action arguing that the Decedent lacked the requisite mental capacity or was unduly influenced by his son when he transferred the land. Specifically, the Estate requested that the court compel the Decedent’s son to make application to the Secretary of the Interior for the transfer of the Indian trust property to the Estate. The circuit court denied the Estate’s request and dismissed the action, determining that it lacked subject matter jurisdiction over the parcels held in trust by the United States. The Supreme Court affirmed, holding that the circuit court did not have jurisdiction over the subject matter of this case. View "Ducheneaux v. Ducheneaux" on Justia Law

After a jury trial, Defendant was convicted of threatening or intimidating a judicial officer, offering a false instrument for filing, and uttering simulated process. The Supreme Court affirmed, holding (1) despite an error in Section A of the brief filed pursuant to State v. Korth on Defendant’s behalf, the unique posture of this case permitted the Court to review his Section B claims of error; and (2) there were sufficient facts for a jury to convict Defendant for threatening or intimidating a judicial officer, offering a false instrument for filing, and uttering simulated process. View "State v. Paulson" on Justia Law

Appellant pleaded guilty to two charges of second degree robbery. The circuit court sentenced Appellant to a term of seven years with two years suspended for the first conviction and a term of eight years with two years suspended for the second conviction. While incarcerated, Appellant signed a suspended sentence supervision agreement. After Appellant received four major rule violations, the Board of Pardons and Paroles concluded that Appellant had violated the conditions of the agreement and ordered that the suspended sentence for the first robbery conviction be revoked and imposed and that the suspended sentence for the second robbery conviction be revoked, imposed, and re-suspended. The Supreme Court affirmed, holding (1) the Board did not exceed its authority in imposing additional conditions that were “not inconsistent” with those placed by the sentencing court; and (2) Appellant failed to establish an equal protection violation because he was not treated differently than a similarly-situated class of inmates. View "Mann v. S.D. Bd. of Pardons & Paroles" on Justia Law

Aaron Terveen was an employee for the South Dakota Department of Transportation. When returning from a work-related trip, Terveen was involved in a one-automobile accident on a dead-end road just off the highway. The Department of Labor awarded workers’ compensation benefits, determining that Terveen sustained an injury arising out of and in the course of his employment. The circuit court reversed, concluding that Terveen’s accident and resulting injuries did not arise out of and in the course of his employment. The Supreme Court affirmed the circuit court’s denial of coverage, holding that Terveen had taken a severable side-trip when he was injured, and the side-trip did not arise of or occur in the course of his employment. View "Terveen v. S.D. Dep’t of Transp." on Justia Law

This case involved an intersection collision between a crop sprayer and a motorcycle. The driver of the crop sprayer was insured through two insurance policies, and the owner of the crop sprayer was insured through a third policy issued by Farm Bureau Mutual Insurance Company. The injured motorcyclists sought damages for their injuries through the insurance policies of the driver and the owner of the crop sprayer. All three insurance companies sought declaratory judgment that they had no duty to defend or indemnify the driver. The circuit court ruled that Farm Bureau had a duty to defend and indemnify the driver on the claims from the collision. The Supreme Court reversed, holding that the language of the Farm Bureau policy unambiguously provided that no coverage existed for the claims against the driver. View "Berkley Reg’l Specialty Ins. Co. v. Dowling Spray Serv." on Justia Law

After a jury trial, Defendant was convicted on two counts of intentional damage to property and one count each of reckless burning, possession of a controlled substance, and possession of marijuana. The Supreme Court (1) reversed and remanded for a new trial on the intentional damage charges so that a jury may determine Rosales’s intent, holding that the circuit court erred in failing to dismiss the intentional damage charges where the jury did not determine whether Defendant acted with intent to destroy the vehicles; and (2) affirmed as to the remainder of the judgment, holding that the circuit court did not err in denying Defendant’s motion to quash the search warrant and suppress the evidence. View "State v. Rosales" on Justia Law

After a jury trial, Defendant was convicted of first-degree rape, aggravated incest, and sexual contact with a child under age thirteen. The Supreme Court affirmed in part and remanded in part, holding (1) the circuit court did not err when it determined that Defendant’s interview with law enforcement was noncustodial; (2) the circuit court did not err when it ruled that Defendant’s interview statements were voluntary and admissible; (3) the circuit court did not abuse its discretion in allowing certain expert testimony; (4) Defendant was not twice put in jeopardy for the same criminal offense; (5) the circuit court properly denied Defendant’s motion for judgment of acquittal; and (6) the Court could not affirmatively say a new trial was warranted because of the State’s failure to provide certain evidence to Defendant. Remanded with instructions for the State to disclose the evidence to Defendant and the circuit court and for the circuit court to enter findings of fact and conclusions of law as to whether there was a Brady violation and, if there was a violation, whether a new trial was warranted. View "State v. Johnson" on Justia Law