Justia Criminal Law Opinion Summaries

In this case, the defendant was convicted of first-degree burglary and aggravated assault with a deadly weapon following an incident where he entered the victim’s home and threatened him with a firearm. The defendant and the victim had a prior relationship as landlord and tenant; the defendant had been storing personal property in a unit owned by the victim, who later sold the storage units and informed the defendant to remove his belongings. Several months after the sale, the defendant confronted the victim at his home, allegedly threatening his life and causing physical harm. The victim reported the incident to law enforcement, and the defendant was subsequently arrested in the vicinity. No firearm matching the victim’s description was found, but the victim's emotional state and the sequence of events were corroborated by other witnesses.The case went to trial in the Circuit Court of the Seventh Judicial Circuit, Pennington County. The defendant sought to impeach the victim’s credibility by referencing the victim’s prior felony convictions, specifically a grand theft conviction and a federal conviction. The circuit court permitted limited cross-examination regarding the existence of two felony convictions, one involving dishonesty, but did not allow further details about the crimes. The court also limited the extent of the defendant’s questioning after the victim described his crime as “white collar.” The jury found the defendant guilty on both counts.The Supreme Court of the State of South Dakota reviewed whether the circuit court abused its discretion by limiting evidence of the victim’s prior convictions, whether the defendant’s confrontation rights were violated, and whether the court erred in responding to a jury question. The Supreme Court held that, while the circuit court’s “blanket rule” limiting impeachment was an abuse of discretion under evidentiary rules, the error was not prejudicial. The Supreme Court affirmed the lower court’s rulings and the convictions. View "State v. Kujawa" on Justia Law

In this case, the petitioner was convicted after a second jury trial on three counts of rape of a minor and one count of sexual contact with a child under sixteen, based on disclosures by his two daughters and their friend. The first trial ended in a mistrial due to a hung jury. After the first trial, his original defense counsel retired and new counsel was appointed. The petitioner was found guilty after retrial and sentenced to three consecutive life sentences plus fifteen years. His convictions were affirmed on direct appeal.After the appellate decision, he filed a pro se habeas corpus application raising ten grounds for relief, including ineffective assistance of counsel and actual innocence, and sought appointment of counsel. The Warden moved to dismiss the application for failure to state a claim and on res judicata grounds. The habeas court dismissed all claims without a hearing or appointing counsel, finding some claims precluded by prior litigation and others speculative or unsupported by specific facts. The court found no basis for appointing counsel or holding an evidentiary hearing.The Supreme Court of South Dakota granted a certificate of probable cause for appeal on four issues. On appeal, the petitioner, represented by appointed counsel, only argued two of the certified issues: ineffective assistance for failure to obtain a psychiatric evaluation of the victims and failure to assert his speedy trial right. The Supreme Court held that a habeas application must meet a minimum threshold of plausibility, with specific, non-conclusory allegations. The Court affirmed the dismissal, holding that the petitioner failed to establish deficient performance or prejudice regarding the psychiatric evaluation and speedy trial claims, and deemed the other certified issues abandoned by not briefing them. The habeas court’s dismissal was affirmed. View "Guzman v. Sullivan" on Justia Law

The defendant and the victim were longtime friends who spent time drinking together over two days in August 2023. After a night and morning of drinking, they visited a farmstead to help a friend with a vehicle. During the visit, the victim unexpectedly put the defendant in a chokehold, briefly rendering him unconscious. After regaining his feet, the defendant grabbed a two-by-four board and chased the victim, who ran away. The defendant struck the victim multiple times with the board, continuing the assault after the victim fell to the ground. The victim sustained severe injuries, including a fractured skull and multiple broken bones, and died the following day from traumatic brain injury.The State charged the defendant with multiple offenses, including second-degree murder and first-degree manslaughter. Prior to trial, the defendant moved to dismiss the indictment, asserting immunity from prosecution under South Dakota’s self-defense statutes. The Circuit Court for the Third Judicial Circuit (Grant County) denied the motion after finding the State had produced clear and convincing evidence that the defendant was not acting in lawful self-defense. The court also excluded certain testimony about the victim’s alleged prior acts while allowing some evidence of past violence and the victim’s criminal history. The case proceeded to a jury trial, resulting in a conviction for first-degree manslaughter and a sentence of 60 years, with 20 years suspended.On appeal, the Supreme Court of South Dakota held that the issue of pretrial denial of statutory immunity was moot following the defendant’s conviction, as the harm sought to be avoided—prosecution—had already occurred. The court also found no abuse of discretion in the exclusion of certain other acts evidence, no error in denying the motion for judgment of acquittal, and no cumulative error depriving the defendant of a fair trial. The conviction and sentence were affirmed. View "State v. Bendel" on Justia Law

The case concerns an incident in which a man was shot and killed in a parking lot after a confrontation with the defendant. The defendant, who was lawfully in his truck, was approached by the victim, who appeared agitated and slapped the defendant multiple times through the truck window. The defendant exited his vehicle with a handgun, chambered a round, and continued to be slapped by the victim, who then stepped back, raised his arms, and challenged the defendant to shoot him. After a brief pause, the defendant shot the victim in the chest, resulting in the victim’s death. Eyewitnesses and a cell phone video captured much of the sequence, and the defendant claimed he acted in self-defense.The Circuit Court of the Seventh Judicial Circuit, Pennington County, held a pretrial evidentiary hearing to consider the defendant’s motion to dismiss the charges based on statutory immunity under South Dakota’s self-defense laws. The court found that the state had rebutted the defendant’s prima facie claim of immunity by clear and convincing evidence, concluding that any threat of harm had dissipated before the fatal shot was fired. At trial, after hearing all the evidence—including the defendant’s testimony and the cell phone video—the jury found the defendant guilty of first-degree manslaughter. The circuit court denied his motions for judgment of acquittal and sentenced him to thirty years in prison.On appeal, the Supreme Court of the State of South Dakota addressed two issues: the sufficiency of the evidence supporting the conviction and whether the denial of statutory immunity as a pretrial matter was reviewable after conviction. The court held that the evidence was sufficient for a rational jury to find the defendant guilty beyond a reasonable doubt and that his use of deadly force was not justified under the circumstances. The court further held that the question of pretrial immunity becomes moot following a final judgment of conviction, as no effectual relief can be granted post-trial. The conviction was affirmed. View "State v. Braveheart" on Justia Law

A police officer in Aberdeen, South Dakota, stopped a driver after observing him make a right turn at an intersection. The officer initiated the traffic stop because he believed the driver had violated a statute requiring a turn signal to be activated for at least 100 continuous feet before turning. The stop led to an arrest for driving under the influence, and a subsequent blood test showed a high blood alcohol concentration. The driver moved to suppress the evidence, arguing that the officer lacked legal justification for the stop because the relevant traffic law did not require a turn signal under the circumstances.The magistrate court held a suppression hearing and denied the motion, finding the statute required use of a turn signal for at least 100 feet before any turn. A court trial on stipulated facts followed, resulting in a conviction for DUI. The driver appealed to the Circuit Court for the Fifth Judicial Circuit, which affirmed the magistrate’s decision. The Circuit Court determined the officer had reasonable suspicion to stop the vehicle based on his observation of what he believed to be a traffic violation, and concluded that the statutory language encompassed the circumstances of the stop.Upon review, the Supreme Court of the State of South Dakota reversed. The Supreme Court held that the statutes governing turn signals require a signal only when another vehicle may be affected by the turn, and that the officer’s belief that a signal was always required was an objectively unreasonable mistake of law. Because the officer did not have reasonable suspicion based on a valid interpretation of the law, the stop was unconstitutional. The Supreme Court reversed the lower courts’ rulings and remanded the case for further proceedings. View "State v. Hawley" on Justia Law

A man lived with his girlfriend in an apartment in Pierre, South Dakota, where they invited a teenage girl to spend time with them. On the evening in question, the group played cards and drank alcohol, but tensions arose, particularly between the man and the girl. After two friends left the apartment, the girlfriend became ill and went to the bathroom, followed by the girl to assist her. The man entered the bathroom, argued with the girl, and the girlfriend fled to seek help. Police responded to 911 calls shortly thereafter, encountered the man at the apartment, and noticed blood on him. Upon entry, police discovered the girl’s body in the bathroom, having suffered multiple stab wounds. The man was arrested, and forensic evidence linked him to the crime scene and the murder weapon.The Circuit Court of the Sixth Judicial Circuit, Hughes County, presided over the trial. During jury selection, the State used a peremptory strike to remove a Native American juror, prompting a Batson challenge from the defense. The circuit court accepted the State’s race-neutral justifications—prior negative interactions with law enforcement and criminal history—as valid reasons for the strike and allowed it to stand. At trial, the man testified, offering conflicting accounts of the events. The jury acquitted him of first-degree murder and aggravated assault but convicted him of second-degree murder, resulting in a life sentence.The Supreme Court of the State of South Dakota reviewed the appeal. It held that the circuit court did not clearly err in allowing the State’s peremptory strike, finding the reasons provided to be race-neutral and not pretextual. It also concluded that the State’s closing argument comments did not constitute improper vouching or prosecutorial misconduct. The conviction and sentence were affirmed. View "State v. Shangreaux" on Justia Law

An eight-year-old girl, A.R., disclosed to her mother that she had been sexually abused by her thirty-year-old half-brother, Tell Cadotte, over a two-year period. After reporting the abuse to the police, A.R. underwent a forensic interview, during which she described the abuse and produced drawings depicting the incidents. Law enforcement obtained a search warrant for Cadotte’s home, where they seized several electronic devices. Forensic examination of these devices revealed over 300 images and videos of child pornography, including multiple pictures that apparently depicted A.R. being abused. Cadotte was charged with multiple counts of first-degree rape and one count of sexual contact with a minor.After a federal conviction for possession of child pornography, Cadotte proceeded to trial in the Circuit Court of the Seventh Judicial Circuit in Pennington County, South Dakota. During trial, defense counsel objected to the admission of certain sanitized photographs, arguing the State had committed a discovery violation by not providing all the images intended for use. The defense also objected to testimony from a detective recounting the victim’s mother’s identification of A.R. in the photographs, claiming it was inadmissible hearsay. The court admitted the evidence, and the jury convicted Cadotte on nine counts of first-degree rape and one count of sexual contact with a minor. The court acquitted him on one rape count for insufficient evidence and sentenced him to seventy years, concurrent with a ten-year term for sexual contact, but consecutive to his federal sentence.On appeal, the Supreme Court of the State of South Dakota held that there was no discovery violation because the State had complied with its statutory obligations, and the defense had access to the evidence in question. The court also held that even if the detective’s testimony was hearsay, its admission was not prejudicial since it was cumulative of other admissible testimony. The convictions were affirmed. View "State v. Cadotte" on Justia Law

A jury found the defendant guilty of third-degree rape in September 2020. The circuit court entered a judgment of conviction in January 2021, sentencing him to ten years in the penitentiary with seven years suspended. The defendant did not appeal his conviction or sentence. He was released from the penitentiary on parole in March 2022. In January 2023, while still on parole, the defendant moved for a sentence reduction, requesting a suspended imposition of sentence. The circuit court granted this motion, placing him on probation.The State objected, first moving for reconsideration on the grounds that the circuit court lacked authority to grant a suspended imposition of sentence after a judgment of conviction and that this would improperly remove the defendant from executive supervision. The circuit court denied the State’s motion and entered an order granting the suspended imposition of sentence. The State appealed, but the Supreme Court of South Dakota dismissed the appeal for lack of statutory appellate jurisdiction. The State then filed a motion to correct an illegal sentence, which the circuit court again denied. The State petitioned for a discretionary appeal, which the Supreme Court of South Dakota granted.The Supreme Court of South Dakota held that the circuit court erred in concluding that res judicata barred the State’s challenge, as the State had not previously had an opportunity for appellate review. The Supreme Court further held that neither SDCL 23A-27-19 nor SDCL 23A-31-1 authorized a circuit court to vacate a judgment of conviction in order to grant a suspended imposition of sentence after a sentence has been imposed. Accordingly, the Supreme Court reversed the circuit court’s order suspending the imposition of the defendant’s sentence. View "State v. Pickner" on Justia Law

Two Sioux Falls police officers attempted to stop a stolen vehicle driven by a suspect who had absconded from parole and was believed to be armed. During a subsequent foot chase, the suspect allegedly shot at the officers, injuring one, and later exchanged gunfire with other law enforcement before being apprehended. After his arrest, the Minnehaha County State’s Attorney filed criminal charges, and the unredacted names of the two officers appeared in public court documents. The officers, invoking their rights as crime victims under Article VI, § 29 of the South Dakota Constitution (Marsy’s Law), requested that their names and any identifying information be redacted from public filings, citing concerns about potential harassment or targeting.Initially, the officers sought relief through a writ of mandamus, which was denied by a judge outside the circuit, who found that Marsy’s Law and South Dakota statutes provided an adequate remedy within the ongoing criminal proceedings. The officers then intervened directly in the criminal case, moving to have their names redacted. The Second Judicial Circuit Court denied their motion, reasoning that Marsy’s Law did not expressly provide a right to anonymity and that, even if the officers were assumed to be “victims,” their names alone did not constitute protected information under Marsy’s Law.On appeal, the Supreme Court of the State of South Dakota reversed and remanded. The Court held that law enforcement officers can qualify as “victims” under Marsy’s Law when a crime is committed against them. It further held that a victim’s name or initials are “information or records that could be used to locate or harass the victim or the victim’s family” and may be subject to redaction upon request. However, the Court clarified that Marsy’s Law does not grant a categorical right to redaction; rather, courts must balance victims’ rights with defendants’ and the public’s constitutional rights on a case-by-case basis. View "State v. Albaidhani" on Justia Law

Susan and Richard Spry managed their uncle Richard Hermanek’s finances under a power of attorney after he suffered from significant cognitive decline. Acting in this capacity, the Sprys opened a joint bank account with Mutual of Omaha in Nebraska, titling it in the names of Hermanek, Susan, and Richard, and transferred large sums from Hermanek’s South Dakota accounts, proceeds from his home, and other funds. After Hermanek’s death, Susan transferred the remaining balance to the Sprys’ personal account in Texas. Concerned relatives who would have inherited from Hermanek initiated a civil suit and notified authorities, leading to a criminal investigation.A Bon Homme County grand jury indicted the Sprys on multiple counts, including grand theft and conspiracy to commit grand theft related to the handling of Hermanek’s property. After a jury trial in the Circuit Court of the First Judicial Circuit, both were convicted on these charges, among others. At trial, the court instructed the jury on contractual rather than testamentary capacity regarding the joint account and limited testimony about Hermanek’s statements during the account’s creation. The court also instructed the jury that the presumption of survivorship rights in a joint account could be rebutted by clear and convincing evidence of contrary intent, rather than requiring proof beyond a reasonable doubt.On appeal, the Supreme Court of the State of South Dakota held that the circuit court did not err in choosing the contractual capacity instruction but erred by excluding testimony about Hermanek’s contemporaneous statements and by using the clear and convincing evidence standard instead of the beyond a reasonable doubt standard for rebutting the presumption of survivorship rights. The Supreme Court reversed the convictions for grand theft and conspiracy to commit grand theft and remanded for further proceedings. View "State v. Spry" on Justia Law