Justia Criminal Law Opinion Summaries

Maxton Pfeiffer shot and killed his friend Ty Scott while they were at their friend Cody Siemonsma’s apartment. Pfeiffer admitted to sweeping Siemonsma’s .45 caliber pistol in Scott’s direction and discharging it, believing it was unloaded after checking it. Pfeiffer was charged with first-degree manslaughter. He argued that the circuit court erred by not instructing the jury that the State had to prove criminal intent beyond a reasonable doubt, by refusing a mistake of fact instruction, and challenged an evidentiary ruling and the sufficiency of the evidence.The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, held a seven-day trial. The jury found Pfeiffer guilty of first-degree manslaughter. Pfeiffer appealed, asserting errors in jury instructions, the exclusion of a deputy state’s attorney’s statement, and the sufficiency of the evidence.The Supreme Court of the State of South Dakota reviewed the case. The court held that the jury instructions, when viewed as a whole, correctly stated the law and adequately informed the jury of the State’s burden to prove criminal intent beyond a reasonable doubt. The court also found that the circuit court did not abuse its discretion in refusing to give a mistake of fact instruction, as the instructions given sufficiently allowed Pfeiffer to present his defense. Additionally, the court ruled that the circuit court did not abuse its discretion in excluding the deputy state’s attorney’s statement, as it was minimally relevant and potentially confusing to the jury. Finally, the court concluded that the evidence was sufficient to sustain Pfeiffer’s conviction, as a rational jury could find that Pfeiffer acted recklessly. The Supreme Court affirmed the conviction. View "State v. Pfeiffer" on Justia Law

Matthew Fuller was convicted of possessing more than two ounces but less than one-half pound of marijuana, a felony, and was placed on supervised probation. After two subsequent arrests, the State petitioned to revoke his probation. The court appointed two attorneys for Fuller, both of whom withdrew. The court did not appoint a third attorney and conducted the revocation hearing with Fuller representing himself. Fuller was found to have violated his probation and was sentenced to a previously suspended two-year prison term.The Circuit Court of the Third Judicial Circuit in Codington County, South Dakota, initially handled the case. Fuller was arrested following a traffic stop and charged with marijuana possession. He was released on bond and represented by multiple attorneys who withdrew. Fuller pled guilty to a lesser charge, and the court imposed a suspended sentence with probation. After his subsequent arrests, the court ordered him held without bond pending the revocation hearing. Fuller’s attorneys withdrew due to a breakdown in the attorney-client relationship, and the court did not appoint new counsel.The Supreme Court of the State of South Dakota reviewed the case. The court held that while Fuller was entitled to appointed counsel under state law, he did not demonstrate that the lack of counsel prejudiced the outcome of the revocation hearing. The court found sufficient evidence to support the probation violation, including Fuller’s use of methamphetamine. The court also rejected Fuller’s claims of judicial bias and due process violations, affirming the lower court’s decision to revoke his probation and execute the suspended sentence. View "State V. Fuller" on Justia Law

Two defendants, Michael Waldner, Jr., and Mark Waldner, were indicted in Brule County, South Dakota, on charges of rape and sexual contact involving a minor, E.H. During the investigation, law enforcement obtained a journal written by E.H. detailing the alleged misconduct. The defendants sought additional journals and diaries written by E.H. through a subpoena duces tecum. E.H. moved to quash the subpoena, but the circuit court denied the motion and ordered an in-camera inspection of the journals. E.H. then filed a petition for an intermediate appeal to the South Dakota Supreme Court.The circuit court initially granted the defendants' motion for further discovery, ordering the State to acquire the journals for an in-camera inspection. E.H. filed a motion to quash the subpoena, asserting her right to privacy under Marsy’s Law. The court vacated its initial discovery order but allowed the defendants to reissue the subpoena. E.H. again moved to quash, but the court denied her motion, leading to her appeal.The South Dakota Supreme Court reviewed the case and determined it had jurisdiction to hear the appeal under SDCL 15-26A-3(4), as the circuit court’s order was a final order affecting a substantial right made in a special proceeding. The court concluded that E.H.’s right to privacy under Marsy’s Law is not absolute and must be balanced against the defendants’ constitutional rights. However, the court found that the circuit court erred by not applying the Nixon factors (relevancy, admissibility, and specificity) when denying E.H.’s motion to quash. The court reversed the circuit court’s order and remanded for further proceedings consistent with its opinion. View "State V. Waldner" on Justia Law

Arnson Absolu was convicted by a jury of three counts of first-degree murder for the deaths of Ashley Nagy, Charles Red Willow, and Dakota Zaiser. The murders occurred in Rapid City, South Dakota, in August 2020. Nagy and Red Willow were found shot in a parked SUV, while Zaiser’s body was later discovered in a shallow grave near Sheridan Lake. Surveillance footage and witness testimonies linked Absolu to the crimes, including evidence of his involvement in the local drug trade and a substantial drug debt owed by Red Willow to Absolu.The Circuit Court of the Seventh Judicial Circuit in Pennington County, South Dakota, presided over the trial. After the trial, Absolu moved for a new trial, claiming that the State had failed to disclose information about a State witness, Shamar Bennett, who was involved in an unrelated infant-death investigation. Absolu argued that this non-disclosure violated his due process rights and the court’s pretrial discovery order. The circuit court denied the motion, finding that although the information should have been disclosed, its absence did not prejudice Absolu’s defense.The Supreme Court of the State of South Dakota reviewed the case. The court affirmed the circuit court’s decision, holding that the undisclosed information about Bennett’s involvement in the infant-death investigation was not material to the outcome of the trial. The court noted that Bennett’s testimony was consistent with his grand jury testimony, which predated the infant-death incident, and that Absolu had already effectively impeached Bennett’s credibility during the trial. The court concluded that there was no reasonable probability that the outcome of the trial would have been different had the information been disclosed. View "State v. Absolu" on Justia Law

Danny Washington was convicted by a jury on multiple charges, including first-degree kidnapping, injury to personal property, and several counts of aggravated and simple assault. The charges stemmed from incidents involving his then-girlfriend, J.B., in October 2021. Washington allegedly assaulted J.B., damaged her vehicle, and forcibly confined her with a firearm, leading to his arrest and subsequent indictment on eight counts.The Circuit Court of the Second Judicial Circuit in Minnehaha County, South Dakota, presided over the trial. Washington filed several pretrial motions, including motions to exclude references to his parole status and to prevent the use of the term "victim" in court. The court granted these motions but denied his request for a personal copy of the discovery. During the trial, the jury found Washington guilty on all counts. Washington later filed a motion for a new trial, citing ineffective assistance of counsel and other trial errors, which the court denied. He was sentenced to 100 years for kidnapping, with additional concurrent and consecutive sentences for other charges.The Supreme Court of South Dakota reviewed the case. Washington argued ineffective assistance of counsel, insufficient evidence for the kidnapping conviction, cumulative trial errors, discrepancies between the oral and written sentences, and improper multiple convictions for aggravated assault. The court declined to address the ineffective assistance claim on direct appeal, noting the need for a more developed record. It found sufficient evidence to support the kidnapping conviction and determined that the alleged trial errors did not cumulatively deny Washington a fair trial. The court clarified that the written sentence, which suspended 60 years of the 100-year kidnapping sentence, controlled over any ambiguous oral pronouncements. Finally, the court held that entering multiple convictions for a single statutory offense arising from the same act violated double jeopardy principles, but found no plain error due to the lack of clear precedent. The court affirmed the lower court's decisions. View "State v. Washington" on Justia Law

Christopher Schocker was convicted of aggravated assault against a law enforcement officer. The incident occurred when Officer Blake Swanson, a Game, Fish, and Parks conservation officer, received a tip about a poached deer and went to investigate. At the scene, Schocker, his mother Doris, and two other individuals were present. During the encounter, Schocker picked up a knife and moved towards Officer Swanson, who then arrested him. Schocker claimed he intended to cut a tag off the deer, not assault the officer.The Circuit Court of the Fifth Judicial Circuit in Roberts County, South Dakota, found Schocker guilty. Schocker appealed, arguing ineffective assistance of counsel. His attorney, Robert Doody, did not interview key witnesses or adequately prepare for trial. The court-appointed new counsel for Schocker, who then filed for habeas corpus relief. The habeas court found that Doody’s performance was deficient and prejudicial, as he failed to interview witnesses who could have supported Schocker’s defense.The Supreme Court of South Dakota reviewed the case. The court affirmed the habeas court’s decision, agreeing that Doody’s failure to interview witnesses, particularly Jeffry Hopkins, who could testify that Schocker intended to cut the tag off the deer, constituted ineffective assistance of counsel. This failure was deemed prejudicial because it deprived Schocker of a fair trial. The court concluded that there was a reasonable probability that the outcome would have been different if the jury had heard Hopkins’s testimony. View "Schocker v. Fluke" on Justia Law

A Sturgis police officer stopped a vehicle for a headlamp violation. The driver, who lacked identification, was found with methamphetamine and drug paraphernalia and was arrested. Wanda Edwards, the passenger, refused to hand over her purse during a vehicle search. Law enforcement forcibly took and searched the purse, finding methamphetamine and drug paraphernalia. Edwards was charged with possession of a controlled substance, possession of marijuana, and obstructing a law enforcement officer. She moved to suppress the evidence found in her purse, but the motion was denied, and she was convicted.The Circuit Court of the Fourth Judicial Circuit in Meade County, South Dakota, denied Edwards' motion to suppress, ruling that the search of the vehicle and its contents, including Edwards' purse, was lawful as it was incident to the driver's arrest. The court concluded that the purse was a container within the vehicle at the time of the arrest, and Edwards' attempt to remove it did not change its status.The Supreme Court of the State of South Dakota reviewed the case. Edwards argued that the search of her purse violated her Fourth Amendment rights, citing that probable cause to search a vehicle does not extend to a passenger's person. The State argued that the search was justified under the automobile exception and as a search incident to arrest. The court held that the search of Edwards' purse was lawful under the automobile exception, as probable cause to search the vehicle extended to all containers within it, including personal belongings of passengers. The court affirmed the lower court's decision, upholding Edwards' convictions. View "State v. Edwards" on Justia Law

Joshua Jay Rose was charged with simple assault of his son, C.R., and faced trial in magistrate court. The first jury trial ended in a mistrial after the jury was deadlocked. During the second trial, the State moved for a mistrial due to defense counsel's references to the previous trial, mention of a no-contact order, and questions about how the trial's outcome could affect where C.R. lived. The magistrate court granted the mistrial, citing the cumulative effect of these issues. Rose's motion to dismiss the charges based on double jeopardy was denied, and he was convicted in a third trial.Rose appealed to the circuit court, arguing that the magistrate court abused its discretion by granting the second mistrial and that double jeopardy should have precluded his retrial. The circuit court affirmed the magistrate court's decision, finding no abuse of discretion.The Supreme Court of South Dakota reviewed the case and affirmed the lower courts' decisions. The court held that the magistrate court did not abuse its discretion in granting the mistrial, considering the cumulative effect of the references to the previous trial, the no-contact order, and the questions about the trial's impact on C.R.'s living situation. The court found that these issues could have affected the jury's impartiality, justifying the mistrial and subsequent retrial. View "State v. Rose" on Justia Law

R.M., a minor, reported that Troy O’Brien, her mother’s boyfriend, had inappropriately touched her breasts and genital area on multiple occasions. O’Brien was charged with multiple counts of rape, sexual contact with a child under sixteen, and sexual exploitation of a minor. A jury found him guilty on all charges. O’Brien appealed, arguing insufficient evidence of sexual penetration and that the rape charges were duplicitous, claiming the court erred by not instructing the jury to unanimously agree on each act of rape.The Circuit Court of the Second Judicial Circuit in Lincoln County, South Dakota, heard the case. During the trial, R.M. testified about multiple instances of inappropriate touching by O’Brien, describing the touching in detail and indicating that it occurred in various rooms of their homes. Despite her difficulty in recalling specific details, R.M. consistently described the nature of the touching. The jury found O’Brien guilty on all counts, and he was sentenced to fifty years for second-degree rape, with additional concurrent sentences for other charges.The Supreme Court of the State of South Dakota reviewed the case. The court held that there was sufficient evidence for a rational jury to conclude that sexual penetration occurred, based on R.M.’s testimony and drawings. The court also addressed the issue of the unanimity instruction, noting that although the charges were duplicitous, O’Brien failed to show that the lack of a specific unanimity instruction affected his substantial rights or the trial's fairness. The court affirmed the lower court’s decision, upholding O’Brien’s convictions and sentences. View "State v. O’Brien" on Justia Law

Cody Heer was convicted of multiple drug-related offenses after selling methamphetamine to a confidential informant in a Walmart parking lot in Sioux Falls, with his child present. Heer was indicted on charges of distributing a controlled substance, possession of a controlled substance, and causing a child to be present where methamphetamine is distributed. The State also filed a habitual offender information due to Heer’s prior felony convictions.Initially represented by court-appointed counsel, Heer moved to represent himself after his request for substitute counsel was denied. The Circuit Court of the Second Judicial Circuit in Minnehaha County granted his motion for self-representation but appointed his former attorney as standby counsel. Heer did not object to this arrangement or to the presence of standby counsel at trial. Heer conducted his defense, including making motions, cross-examining witnesses, and delivering closing arguments. The jury found Heer guilty on all counts, and he was sentenced to fifteen years in prison for the distribution conviction, with additional suspended sentences for the other charges.The Supreme Court of the State of South Dakota reviewed Heer’s appeal, where he argued that his Sixth Amendment right to self-representation was violated by the appointment and presence of standby counsel. Heer also claimed that the prosecutor’s statements during closing arguments constituted improper vouching, amounting to plain error. The court held that the appointment of standby counsel was permissible and did not violate Heer’s rights, as standby counsel did not interfere with his control over the case. The court also found no merit in Heer’s claims of improper vouching, concluding that the prosecutor’s statements were fair characterizations of the evidence and did not affect the trial’s outcome. The court affirmed Heer’s convictions and sentences. View "State V. Heer" on Justia Law