Justia Criminal Law Opinion Summaries

Articles Posted in South Dakota Supreme Court
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The Supreme Court affirmed Defendant's conviction of third-degree rape, holding that the State did not violate Defendant's right to due process by failing to interview the victim and that the circuit court did not err in determining that knowledge is not an element of the offense.Defendant was found guilty of third-degree rape in violation of S.D. Codified Laws 22-22-1(3), which makes it a crime for any person to sexually penetrate a victim incapable of giving consent because of physical or mental incapacity. The Supreme Court affirmed, holding that the circuit court (1) did not err when it denied Defendant's motion to dismiss; (2) did not err when it determined that knowledge is not an element of section 22-22-1(3); (3) did not abuse its discretion in restricting certain testimony; and (4) did not abuse its discretion when it denied Defendant's motion for a continuance. View "State v. Jackson" on Justia Law

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The Supreme Court affirmed Defendant's conviction of second-degree rape and sexual contact involving a second victim, holding that Defendant's allegations of error were unavailing.Specifically, the Supreme Court held (1) the circuit court did not abuse its discretion by allowing evidence of Defendant's two prior alleged sexual assaults; (2) the admission of other act evidence did not violate Defendant's constitutional rights under the Double Jeopardy and Due Process Clauses; (3) the circuit court did not abuse its discretion when it denied Defendant's motion for a mistrial; (4) there was sufficient evidence to support the conviction; (5) the circuit court erred in admitting forensic laboratory reports by affidavit without affording Defendant the opportunity to cross-examine the analysts who conducted the testing and authored the reports, but the error was not prejudicial; and (6) Defendant's sentence did not violate the Eighth Amendment. View "State v. Taylor" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of aggravated assault and three counts of simple assault and ordering him to pay restitution to Medicaid for its coverage of the victim's medical expenses, holding that the circuit court did not err.Specifically, the Supreme Court held that the circuit court (1) did not commit plain error in finding that Medicaid qualified as a victim for purposes of restitution under S.D. Codified Laws 23A-28-2(5); (2) did not commit plain error by permitting testimony from two detectives that Defendant did not act in self-defense; and (3) did not abuse its discretion in denying Defendant's motion for a mistrial based on the prosecutor's statements during closing argument. View "State v. Bryant" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Defendant's motion to suppress evidence obtained as a result of his encounter with police, holding that the circuit court properly denied the motion to suppress.Defendant was charged with possession of controlled substances, a loaded firearm while intoxicated, marijuana, and drug paraphernalia. Defendant filed a motion to suppress evidence obtained from a stop of his person on the basis that it violated the Fourth Amendment. The circuit court denied the motion, concluding that the search was done in accordance with Terry v. Ohio, 392 U.S. 1 (1968) and its progeny. The Supreme Court affirmed, holding (1) under the totality of the circumstances, the officers had reasonable suspicion to stop Defendant; and (2) therefore, the circuit court did not err by denying Defendant's motion to suppress. View "State v. Williams" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of second-degree murder and sentencing him to ninety years in prison, holding that Defendant's discretionary sentence did not offend the Eighth Amendment's prohibition against cruel and unusual punishment.Defendant pled guilty to second-degree murder. He was seventeen years old when he committed the crime. The circuit court sentenced Defendant to ninety years in prison, making him eligible for parole at age sixty-two. On appeal, Defendant argued that his sentence was unconstitutional because it violated categorical Eighth Amendment sentencing restrictions for juveniles and because it was disproportionately harsh. The Supreme Court disagreed, holding (1) because the court did not sentence Defendant to a mandatory life sentence and sufficiently considered his youth when fashioning his sentence, there was no Eighth Amendment violation; and (2) Defendant did not meet the initial requirement to show that his sentence was grossly disproportionate to his crime. View "State v. Quevedo" on Justia Law

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The Supreme Court affirmed Defendant's conviction of aggravated assault (domestic), simple assault (domestic), interference with emergency communications, and disorderly conduct but remanded with instructions to issue a new judgment removing the domestic designation from Defendant's assault convictions, holding that the court lacked authority to designate the assault conviction as domestic and order payment of the statutory domestic violence fees.Specifically, the Supreme Court held (1) Defendant did not establish plain error through the admission of certain evidence; (2) Defendant did not demonstrate the existence of plain error regarding the prosecutor's closing argument; (3) the circuit court correctly denied Defendant's judgment for acquittal on the assault charges, but the assault convictions should not have been designated as domestic, and the court should not have imposed two $25 domestic violence fees for Defendant's assault convictions; and (4) Defendant did not demonstrate prejudicial error resulting from his absence at a stipulated post-judgment sentence modification meeting. View "State v. Wilson" on Justia Law

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The Supreme Court dismissed this consolidated appeal brought by the State as to each of three jointly indicted defendants from a trial court order dismissing certain counts of the indictment against them, holding that the State has no right of appeal from the dismissal of counts of an indictment or information.Defendants moved to dismiss several counts of the joint indictment on the grounds of multiplicity. The trial court granted the motion as to counts three through sixteen, leaving some counts of the indictment for further proceedings. The State appealed. The Supreme Court dismissed the appeals, holding that S.D. Codified Laws 23A-32-4 does not authorize an appeal of right from a dismissal of individual counts, and therefore, this Court lacked jurisdiction to hear the State's appeals. View "State v. Steffensen" on Justia Law

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The Supreme Court reversed Defendant's the order of the circuit court granting Defendant's motion to suppress evidence obtained as a result of Defendant's arrest, holding that the circuit court erred when it refused to consider the application of the attenuation doctrine and suppressed the evidence.Defendant was charged with possession of methamphetamine and false impersonation. Before trial, Defendant moved to suppress the evidence obtained as a result of her interaction with police officers on the grounds that the officers lacked reasonable suspicion to detain her. The circuit court granted the motion to suppress. Despite the State's argument that the attenuation doctrine applied, the circuit court did not analyze the applicability of the attenuation doctrine. The Supreme Court reversed, holding that because the connection between Defendant's detention and the subsequent search was interrupted by the discovery of the existence of a valid, preexisting and unrelated warrant, the attenuation factors weighed in favor of the State. View "State v. Mousseaux" on Justia Law

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The Supreme Court affirmed Defendant's conviction for possession of a controlled substance, holding that the circuit court judge did not err when he continued to preside over Defendant's case after Defendant filed an affidavit for change of judge.Defendant pleaded guilty to possession of a controlled substance. The circuit court, the Honorable Tony Portra presiding, received Defendant's guilty plea. The Supreme Court reversed. On remand, instead of consulting his appointed counsel, Defendant filed an affidavit for change of judge. Judge Portra denied Defendant's request for change of judge. Thereafter, Defendant pled guilty to one count of possession of a controlled substance. Defendant later filed an application for a writ of habeas corpus. The habeas court granted the writ and ordered that Defendant be resentenced. The court imposed the same sentence. The Supreme Court affirmed, holding (1) Judge Portra violated S.D. Codified Laws 15-12-22 by presiding over the hearing on Defendant's affidavit for a change of judge and determining that Defendant's affidavit was not properly filed; but (2) because Defendant was not entitled to file the affidavit, Judge Portra's non-compliance with section 15-12-22 did not deprive the court of authority to accept Defendant's guilty plea and impose a sentence. View "State v. Hirning" on Justia Law

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The Supreme Court affirmed Defendant's sentence of eighty years imprisonment with forty years suspended for first-degree manslaughter, holding that the sentence was not grossly disproportionate to the offense and did not violate the Eighth Amendment.Specifically, the Supreme Court held (1) Defendant's sentence was not grossly disproportionate to the offense of first-degree manslaughter under the Eighth Amendment; (2) at sentencing, the circuit court properly examined the events surrounding the offense, Defendant's character and history, and Defendant's rehabilitation prospects; and (3) the circuit court did not abuse its discretion in crafting the sentence. View "State v. Holler" on Justia Law