Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the circuit court’s judgment convicting Defendant of first-degree rape, multiple counts of sexual contact with a child, and possessing, manufacturing, or distributing child pornography, holding that the circuit court did not violate Defendant’s right to a public trial when it ordered the partial closure of the courtroom during the minor victim’s testimony.On appeal, Defendant argued that the circuit court erred in partially closing the courtroom in violation of his Sixth Amendment right to a public trial and that the court erred in denying his motion to suppress his non-custodial statement to a law enforcement officer. The Supreme Court affirmed, holding (1) there was no violation of Defendant’s Sixth Amendment right to a public trial; and (2) the absence of any custodial interrogation rendered Defendant’s second argument unsustainable under Miranda v. Arizona, 384 U.S. 436 (1996), and Edwards v. Arizona, 451 U.S. at 485-85 (1990). View "State v. Uhre" on Justia Law

In this criminal case, the Supreme Court affirmed the decision of the circuit court admitting certain other acts evidence and denying Defendant’s motion for a mistrial, holding that the circuit court did not err in admitting the evidence or by denying Defendant’s motion for a mistrial.Defendant was convicted of multiple sex crimes involving two minor victims under the age of sixteen. Among the issues on appeal was the court’s admission of internet searches that used terms associated with an interest in younger females and Defendant’s act of piercing his penis. The Supreme Court affirmed, holding that the circuit court (1) did not abuse its discretion by admitting the internet search histories and piercing evidence; and (2) acted within its discretion when it denied Defendant’s motion for a mistrial after Defendant learned during trial that the bailiff had recently been employed by the State’s attorney. View "State v. Thomas" on Justia Law

The Supreme Court affirmed Defendant’s conviction of first-degree felony murder, commission of a felony while armed with a firearm, and burglary in the first degree, holding that the circuit court properly denied Defendant’s motion to suppress and did not err by refusing to compel specific performance of a plea agreement.On appeal, Defendant argued that his statements to law enforcement during a custodial interrogation should have bene suppressed because they were obtained in violation of his right to counsel and right against self-incrimination. Defendant further claimed that the circuit court erred in denying his motion for specific performance of the plea agreement that he alleged would have allowed him to plead guilty to manslaughter. The Supreme Court affirmed, holding (1) the admission of the evidence that was the subject of the motion to suppress was harmless error even if the statements had been unlawfully obtained; and (2) Defendant failed to show an enforceable plea agreement existed, and therefore, the circuit court properly denied Defendant’s motion for specific performance of the plea agreement. View "State v. Lewandowski" on Justia Law

The Supreme Court affirmed Defendant’s judgment of conviction and sentence for third-degree rape, holding that the circuit court did not err in denying Defendant’s motion to suppress evidence obtained from a warrantless search of his garage, holding that Defendant was not seized for Fourth Amendment purposes at the beginning of his encounter with police deputies and that his consent to search the garage was voluntary.On appeal, Defendant asserted that he was unreasonably seized by deputies before the search took place, and therefore, any consent give to search the garage after the seizure was not voluntary. The Supreme Court disagreed, holding that the deputies’ actions were reasonable, Defendant was not seized as soon as the encounter began, and Defendant’s consent to search the garage was voluntary. View "State v. Rolfe" on Justia Law

The Supreme Court affirmed Defendant’s conviction of two counts of sexual exploitation of a minor and one count of contributing to the abuse, neglect, or delinquency of a minor, holding that the evidence was sufficient to support the jury’s verdict.As his sole issue on appeal, Defendant argued that the circuit court erred by denying his motions for judgment of acquittal because the evidence was factually and legally insufficient to support the verdicts. The Supreme Court affirmed the circuit court’s denial of the motion for judgment of acquittal, holding that the evidence was sufficient to support Defendant’s convictions. View "State v. Livingood" on Justia Law

The Supreme Court affirmed the three consecutive fifteen-year sentences handed down by the circuit court after Appellant pleaded guilty to three counts of aggravated assault, holding that the circuit court did not err by failing to follow the terms of a plea agreement because the plea agreement was not binding on the court.Specifically, Appellant argued that the circuit court improperly failed to follow the terms of the plea agreement limiting the maximum prison term on each count of aggravated assault to ten years. The Supreme Court disagreed, holding (1) the circuit court was not bound by the terms of the plea agreement between Appellant and the State; and (2) because the plea agreement was not binding on the circuit court, it was not necessary to consider whether the circuit court’s sentences were consistent with the terms of the plea agreement. View "State v. Ledbetter" on Justia Law

The Supreme Court affirmed Defendant’s conviction of second-degree murder, holding that the circuit court did not err in denying Defendant’s motion to suppress evidence obtained as a result of an investigatory stop.Prior to trial, the circuit court denied Defendant’s motion to suppress the evidence obtained as a result of the stop, concluding that the arresting law enforcement officer had reasonable suspicion to initiate the investigatory stop. The Supreme Court affirmed, holding that the officer’s suspicion was not grounded on a mere hunch, that the officer articulated facts that supported the quantum of suspicion necessary to initiate an investigatory stop, and that, under the totality of the circumstances, the investigatory stop was based on reasonable suspicion within the meaning of the Fourth Amendment. View "State v. Chase" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant, a truck driver, of operating an overweight truck on a bridge, holding that Defendant’s arguments on appeal were unavailing.Specifically, the Court held that the circuit court (1) did not err in rejecting Defendant’s argument that the truck was not subject to the weight limit posted for the bridge and finding Defendant guilty of violating S.D. Codified Laws 32-22-48; (2) did not err in denying Defendant’s request for a jury trial; and (3) did not err in denying Defendant’s motion to dismiss pursuant to S.D. Codified Laws 23A-44-5.1, otherwise known as the 180-day rule. View "State v. Johnsen" on Justia Law

The Supreme Court affirmed the judgment of the circuit court entering an amended judgment of conviction ordering Defendant’s sentences to run concurrently to his corresponding federal sentences, holding that Defendant had no Sixth Amendment right to counsel in the circuit court proceeding to correct his sentences.Defendant pleaded guilty to kidnapping and assault. Defendant was sentenced to life imprisonment for the kidnapping and thirty years for the assault. The circuit court ordered the sentences to run consecutively to corresponding federal sentences Defendant had received for the same offenses. The Supreme Court reversed and remanded the case for resentencing, holding that a South Dakota state court may not impose a consecutive sentence in state court when a defendant has been sentenced for the same offenses in federal court. After Defendant was resentenced, he argued that the circuit court’s failure to provide court-appointed counsel in the sentence correction proceeding violated his Sixth Amendment right to counsel. The Supreme Court disagreed, holding that the sentence correction proceeding was not a critical stage in which Defendant had a Sixth Amendment right to court-appointed counsel. View "State v. Red Kettle" on Justia Law

The Supreme Court dismissed the State’s intermediate appeal challenging the circuit court’s reversal of the magistrate court’s order denying Defendant’s motion to suppress, holding that there was no basis for an appeal to this Court at the present stage of the proceedings.Defendant was charged with driving under the influence of alcohol. Defendant filed a motion to suppress the evidence obtained from the traffic stop, arguing that police officers lacked reasonable suspicion. The magistrate court denied the motion. Defendant was then convicted and sentenced. Defendant appealed, and the circuit court reversed and remanded the judgment. The State petitioned for an intermediate appeal, arguing that the Supreme Court had jurisdiction to hear an appeal under S.D. Codified Laws 23A-32-5. The Supreme Court dismissed the appeal, holding that no appeal can lie from the circuit court’s remand order. View "State v. Sharpfish" on Justia Law