Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant’s convictions for unauthorized ingestion of a controlled substance and possession of two ounces or less of marijuana but reversed and remanded for a new trial Defendant’s conviction for first-degree manslaughter, holding that the circuit court erred in instructing the jury on first-degree manslaughter.After the State concluded its case-in-chief, Defendant submitted a proposed jury instruction on excusable homicide. The circuit court denied Defendant’s proposed instruction, noting that it was submitted after the State had rested and determining that defendant’s conduct was unlawful. The Supreme Court held that because the evidence presented a theory for the jury’s consideration whether the homicide was accidental and excusable, the circuit court erred in failing to give the excusable homicide instruction, and the error prejudiced Defendant. The Court further held that the circuit court did not abuse its discretion by denying Defendant’s motions for mistrial. View "State v. Randle" on Justia Law

The Supreme Court affirmed the sentence imposed in connection with Defendant’s conviction for third-degree burglary, holding that the sentencing court had authority to alter its original sentence and that Defendant did not establish that the sentencing court abused its discretion in imposing the sentence.After Defendant pleaded guilty to third-degree burglary as part of a plea agreement, the court sentenced him to five years’ imprisonment with three and one-half years suspended. Before exiting the courtroom in the custody of the sheriff, Defendant “flipped off” the circuit court judge. The court then summoned Defendant back to counsel’s table and resentenced him, imposing the entry five-year term. The court then granted a resentencing hearing and imposed a sixty-month sentence with forty months suspended. The Supreme Court affirmed the sentence, holding (1) under the circumstances, no formal break in the proceedings occurred when Defendant made his obscene gesture, and therefore, the circuit court had the authority to modify Defendant’s sentence; and (2) the court properly relied on S.D. Codified Laws 23A-27-19 to reduce Defendant’s five-year sentence to a sentence of sixty months with forty months suspended. View "State v. Ross" on Justia Law

The Supreme Court reversed Defendant’s conviction and sentence for possessing a controlled substance (methamphetamine), holding that the circuit court erred by denying Defendant’s motion to suppress evidence obtained from an illegal search and seizure.On appeal, Defendant argued that the search of his person violated the United States Constitution’s prohibition against unreasonable searches and seizures. The State did not obtain a warrant to search Defendant but argued that the search was valid as an investigatory stop under Terry v. Ohio, 392 U.S. 1 (1968). The Supreme Court disagreed, holding (1) because the State failed to identify a reasonable suspicion of criminal activity, Defendant’s search and seizure could not be justified under Terry; and (2) the consent exception to the Fourth Amendment’s warrant requirement did not apply in this case. View "State v. Kaline" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Defendant’s motion to suppress evidence on the grounds that the police officer lacked reasonable suspicion to initiate an investigatory traffic stop and that the search warrant for a blood sample was invalid under South Dakota law.Defendant appealed from an order entering a suspended imposition of sentence after he was found guilty of driving under the influence of alcohol. The Supreme Court affirmed the denial of Defendant’s motion to suppress, holding (1) the circuit court’s finding that the officer observed the vehicle cross the center line provide the officer reasonable suspicion to initiate the stop; and (2) the warrant obtained for Defendant’s blood draw did not violate the Warrants Clause of the South Dakota Constitution. View "State v. Bowers" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant’s appeal from a letter sent by the South Dakota Board of Pardons and Paroles denying Appellant’s request to review her parole date again.Appellant, a prison inmate, did not appeal from the Board’s adjudication of her initial parole-eligibility date. Two years later, Appellant requested the Board to reconsider. The Board declined, and Appellant filed an administrative appeal in circuit court. The circuit court dismissed the appeal with prejudice, concluding that it lacked subject matter jurisdiction because (1) the Board’s letter was not an appealable “decision, order, or action” within the meaning of S.D. Codified Laws 1-26-30.2; and (2) it did not have subject matter jurisdiction to review the Board’s final parole determination. In affirming, the Supreme Court held (1) the Board’s letter declining an additional review was not a final decision in a contested case that could be appealed to the circuit court; and (2) because Appellant did not appeal the Board’s final determination within thirty days as required by S.D. Codified Laws 1-26-31, the circuit court correctly concluded that it did not have subject matter jurisdiction to hear Appellant’s appeal. View "Peterson v. South Dakota Board of Pardons & Paroles" on Justia Law

The Supreme Court affirmed the order of the habeas court denying Petitioner’s petition for a writ of habeas corpus arguing that his trial counsel’s assistance was ineffective in regard to his decision to plead guilty and in regard to sentencing.Pursuant to a plea agreement, Petitioner pleaded guilty to second-degree robbery. Petitioner did not file an appeal or file a motion to modify his sentence. Instead, he filed a petition for a writ of habeas corpus asking the circuit court to vacate his sentence. The habeas court denied the petition. The Supreme Court affirmed, holding that Petitioner failed to prove that the alleged errors in his trial attorney’s performance “actually had an adverse effect on the defense” under Strickland v. Washington, 466 U.S. at 693 (1984), and therefore, Petitioner was not entitled to relief. View "Madetzke v. Dooley" on Justia Law

The Supreme Court affirmed Appellant’s separate convictions and sentences for aggravated assault and escape. The Court held (1) the circuit court did not err in denying Appellant’s motion to suppress; (2) the circuit court did not err when it denied Appellant a new trial after the jury found him guilty of aggravated assault and guilty of the lesser-included offense of simple assault because the circuit court vacated the jury’s guilty verdict for simple assault; (3) the circuit court did not err when it denied Appellant’s motion for a judgment of acquittal; and (4) the circuit court did not abuse its discretion in certain evidentiary rulings. View "State v. Abdo" on Justia Law

The Supreme Court affirmed the judgment of the habeas court denying Appellant’s petition for a writ of habeas corpus. After a jury trial, Appellant was convicted of second-degree murder and aggravated assault. In his habeas petition, Appellant argued that the circuit court committed errors during the jury selection process that warranted a new trial and that his counsel provided constitutionally ineffective assistance. The habeas court concluded (1) the circuit court committed errors during the jury selection process, but the errors were not structural and Appellant did not prove prejudice; and (2) Appellant failed to prove that counsel was ineffective during the jury selection process. The Supreme Court affirmed, holding (1) the circuit court’s errors during the jury selection process were not structural and were harmless; and (2) Appellant failed to show that he receive ineffective assistance of counsel. View "Miller v. Young" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of second-degree murder. The Court held that the circuit court did not err in (1) failing to dismiss the indictment on the ground that Defendant was not given notice of the coroner’s release of the body because Defendant failed to demonstrate prejudice; (2) denying Defendant’s motion for judgment of acquittal because the evidence was sufficient to support the verdict; and (3) admitting autopsy photographs into evidence because Defendant failed to show that the evidence was unduly prejudicial. View "State v. Quist" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of second-degree murder. The Court held that the circuit court did not err in (1) failing to dismiss the indictment on the ground that Defendant was not given notice of the coroner’s release of the body because Defendant failed to demonstrate prejudice; (2) denying Defendant’s motion for judgment of acquittal because the evidence was sufficient to support the verdict; and (3) admitting autopsy photographs into evidence because Defendant failed to show that the evidence was unduly prejudicial. View "State v. Quist" on Justia Law