Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of three felony drug offenses in connection with the sale of methamphetamine to a confidential informant, holding that the circuit court did not abuse its discretion in denying Defendant's motion for a new trial and that Defendant's sentence did not constitute cruel and unusual punishment under the Eighth Amendment.After a two-day trial, Defendant was convicted of three drug-related offenses. Defendant was sentenced to fifteen years imprisonment for the possession and distribution counts, to run concurrently to each other and to the sentences he was serving, and to twenty-five years for the offense of distribution in a drug free zone, to run consecutively to his other sentences. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion by refusing to admit certain evidence proffered by Defendant; (2) the circuit court did not abuse its discretion in denying Defendant's motion for a new trial; and (3) Defendant's sentence was neither grossly disproportionate to his crimes nor cruel and unusual. View "State v. Shelton" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Appellant's motion for order to show cause why Appellee was not in contempt of the circuit court's judgment and decree of divorce, holding that the circuit court erred when it found that Appellee was not in contempt of court because she was not personally served with the judgment.The circuit court found that Appellee did not comply with a court order but that she could not be found in contempt because she was not given proper notice of the order. The Supreme Court reversed, holding (1) the issue raised on appeal was not moot; and (2) the circuit court clearly erred when it found that Appellee was not in contempt of the order at issue because she did not have knowledge of the contents of the judgment and decree of divorce. View "Metzger v. Metzger" on Justia Law

The Supreme Court affirmed Defendant's sentence to life imprisonment without the possibility of parole in connection with his plea of guilty to aiding and abetting first-degree manslaughter, holding that Defendant's sentence of life without parole was neither an abuse of discretion nor gross disproportionality.On appeal, Defendant challenged his sentence. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion by sentencing Defendant to life in prison without the possibility of parole; and (2) the circuit court's sentence did not amount to cruel and unusual punishment in violation of the Eighth Amendment. View "State v. Klinetobe" on Justia Law

The Supreme Court affirmed Defendant's convictions for vehicular homicide and driving under the influence, holding that the evidence was sufficient to support the convictions and that the circuit court's error in denying Defendant's motion to suppress was harmless.On appeal, Defendant argued that the circuit court erred when it denied her motion to suppress a statement that she made to law enforcement officers at the hospital and when it denied her motion for a judgment of acquittal. The Supreme Court affirmed, holding (1) the circuit court erred by denying Defendant's suppression motion, but the error was harmless given the overwhelming evidence against her; and (2) the evidence was sufficient to sustain Defendant's convictions. View "State v. Angle" on Justia Law

The Supreme Court reversed the judgment of the circuit court reversing the judgment of the Department of Public Safety ordering Appellee's commercial driving privileges to be disqualified for one year, holding that commercial driver's license (CDL) disqualification under S.D. Codified Laws 32-12A-36(4) applies when a vehicle is used as a means to possess a felony quantity of marijuana.The Department disqualified Appellee's commercial driving privileges for one year pursuant to 32-12A-36(4) because he had been convicted of a felony committed in a vehicle by a CDL holder. The circuit court reversed Appellee's CDL disqualification, holding that the statute requires that a vehicle was an "instrumentality" of the felony. The Supreme Court reversed and reinstated the Department's decision, holding (1) possession of a felony quantity of marijuana in a vehicle is "using a...vehicle in the commission of any felony" under section 13-21A-36(4); (2) the circuit court erred by holding that section 13-21A-36(4) was unconstitutionally vague; and (3) there was sufficient evidence to support the Department's disqualification of Appellee's CDL privileges. View "Ibrahim v. Department Of Public Safety" on Justia Law

The Supreme Court reversed Defendant's conviction of driving under the influence of an alcoholic beverage (DUI), holding that the circuit court erred in denying Defendant a preliminary hearing.The State charged Defendant with driving a motor vehicle while under the influence of an alcoholic beverage. Defendant moved for a preliminary hearing. The circuit court denied the motion. The State then filed a supplemental information alleging that Defendant had been convicted of two prior DUIs, thereby charging him with DUI third offense, a Class 6 felony. The plain language of S.D. Codified Laws 23A-4-3 entitles a defendant to a preliminary hearing if he is charged with an offense "punishable as a felony." The Supreme Court reversed Defendant's conviction and remanded the case for further proceedings, holding that because Defendant faced a potential felony conviction he was entitled to a preliminary hearing. View "State v. Rus" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated assault and one count of simple assault against a law enforcement officer, holding that there was no error.On appeal, Defendant claimed, among other things, that her conviction of aggravated assault was unlawful because the gun she was holding at the time of the incident giving rise to her convictions was inoperable. The Supreme Court affirmed, holding that the circuit court (1) did not err by denying Defendant's motion to suppress evidence of Defendant's conduct giving rise to the simple assault charge; (2) did not err, under the circumstances, by not instructing the jury on the definition of a firearm and by prohibiting Defendant's argument regarding firearm operability; and (3) did not err by denying Defendant's motion for judgment of acquittal. View "State v. Schumacher" on Justia Law

The Supreme Court affirmed Defendant's conviction of rape, kidnapping, aggravated assault, burglary, and other offenses, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held that the circuit court (1) abused its discretion in admitting other act evidence from Defendant's ex-wife, but the error did not necessitate reversal; (2) followed the statutory procedures during jury selection such that structural or other reversible error did not occur; (3) did not err in denying Defendant's motion to suppress; and (4) did not abuse its discretion in admitting certain testimony. View "State v. Evans" on Justia Law

The Supreme Court affirmed Defendant's sentence entered after he pled nolo contendere to three counts of possession of child pornography pursuant to a plea agreement, holding that the sentence did not violate the Eighth Amendment or constitute an abuse of discretion.The circuit court sentenced Defendant to ten years' incarceration, with six years suspended on each count and credit for time served. The court ordered counts one and two to be served consecutively with count three to run concurrently. The Supreme Court affirmed, holding (1) Defendant's sentence did not violate the Eighth Amendment's prohibition against cruel and unusual punishment; and (2) the circuit court did not abuse its discretion in sentencing Defendant. View "State v. Miles" on Justia Law

The Supreme Court affirmed Defendant's conviction of criminal solicitation of aiding and abetting first degree murder, holding that the circuit court did not err in denying Defendant's pretrial and post-trial motions, in denying Defendant's requested jury instruction, or in admitting certain testimony.Defendant requested that a friend procure a gun for him so that he could kill a medical doctor who treated his wife. Based on this conduct, Defendant was convicted of criminal solicitation of aiding and abetting first-degree murder. On appeal, Defendant argued, among other things, that the court erred in denying his pretrial and post-trial motions arguing that one cannot criminally solicit another to aid and abet an offense. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Defendant's pretrial and post-trial motions where S.D. Codified Laws 22-4A-1 permits a defendant to be charged with criminal solicitation of aiding and abetting an offense; (2) did not err in instructing the jury on the elements of aiding, abetting, or advising; and (3) erroneously admitted the doctor's testimony, but the error was not prejudicial. View "State v. Thoman" on Justia Law