Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the circuit court granting Defendant’s motion to suppress evidence found in the vehicle Defendant was driving, holding that, contrary to the circuit court’s finding, Defendant’s traffic stop was not unlawfully extended.Defendant was indicted on four felony drug charges after controlled substances were found in the vehicle she was driving. The circuit court granted Defendant’s motion to suppress, determining that the officer that stopped the vehicle unlawfully prolonged the traffic stop to question Defendant, conduct standard field sobriety tests, and call for a drug dog without reasonable suspicion of drug activity. The Supreme Court reversed, holding that the officer’s decision to extend the initial traffic stop to question Defendant about drug activity and to conduct the drug dog sniff was supported by reasonable suspicion, and therefore, the traffic stop was not unlawfully extended. View "State v. Barry" on Justia Law

The Supreme Court reversed the judgment of the circuit court granting Defendant’s motion to suppress evidence found in the vehicle Defendant was driving, holding that, contrary to the circuit court’s finding, Defendant’s traffic stop was not unlawfully extended.Defendant was indicted on four felony drug charges after controlled substances were found in the vehicle she was driving. The circuit court granted Defendant’s motion to suppress, determining that the officer that stopped the vehicle unlawfully prolonged the traffic stop to question Defendant, conduct standard field sobriety tests, and call for a drug dog without reasonable suspicion of drug activity. The Supreme Court reversed, holding that the officer’s decision to extend the initial traffic stop to question Defendant about drug activity and to conduct the drug dog sniff was supported by reasonable suspicion, and therefore, the traffic stop was not unlawfully extended. View "State v. Barry" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree robbery, holding that sufficient evidence supported the conviction.On appeal, Defendant argued that the trial court erroneously admitted a surveillance video of him and an accomplice the day before the robbery. Much of the evidence directly implicating Defendant was elicited from that accomplice. Defendant argued before the Supreme Court that, without the video, there was insufficient evidence to corroborate the accomplice’s testimony. The Supreme Court disagreed, holding that even if the admission of the video was error, the error was harmless because there was evidence independent of the surveillance video that tended to affirm the accomplice’s testimony and establish Defendant’s guilt. View "State v. Dunkelberger" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree robbery, holding that sufficient evidence supported the conviction.On appeal, Defendant argued that the trial court erroneously admitted a surveillance video of him and an accomplice the day before the robbery. Much of the evidence directly implicating Defendant was elicited from that accomplice. Defendant argued before the Supreme Court that, without the video, there was insufficient evidence to corroborate the accomplice’s testimony. The Supreme Court disagreed, holding that even if the admission of the video was error, the error was harmless because there was evidence independent of the surveillance video that tended to affirm the accomplice’s testimony and establish Defendant’s guilt. View "State v. Dunkelberger" on Justia Law

The Supreme Court reversed Defendant’s convictions for first-degree rape and sexual contact with a child under the age of sixteen and remanded this case for a new trial, holding (1) the circuit court did not err in permitting Defendant’s impeachment with inconsistent statements he made to law enforcement in a prior, unrelated criminal investigation; but (2) the circuit court misapplied S.D. Codified Laws 19-19-702 when it precluded Defendant’s expert witness from testifying about the methods used by the forensic interviewer who interviewed the child, and the exclusion of this evidence was sufficiently prejudicial to entitle Defendant to a new trial. View "State v. Wills" on Justia Law

The Supreme Court reversed Defendant’s convictions for first-degree rape and sexual contact with a child under the age of sixteen and remanded this case for a new trial, holding (1) the circuit court did not err in permitting Defendant’s impeachment with inconsistent statements he made to law enforcement in a prior, unrelated criminal investigation; but (2) the circuit court misapplied S.D. Codified Laws 19-19-702 when it precluded Defendant’s expert witness from testifying about the methods used by the forensic interviewer who interviewed the child, and the exclusion of this evidence was sufficiently prejudicial to entitle Defendant to a new trial. View "State v. Wills" on Justia Law

Under the Fourth Amendment, law enforcement may not require an arrestee to urinate into a specimen container as a search incident to a lawful arrest without a valid warrant.Defendant was convicted and sentenced for unauthorized ingestion of a controlled substance. On appeal, Defendant argued that the circuit court erred by denying his motion to suppress evidence produced through chemical analysis of a urine sample that law enforcement obtained without first obtaining Defendant’s consent or a warrant. After considering an arrestee’s legitimate expectation of privacy and the government’s competing interest in preserving evidence, the Supreme Court agreed, holding (1) law enforcement may not, without a warrant, require an arrestee to provide a urine sample as a search incident to arrest; and (2) therefore, the search in this case was unconstitutional, and the circuit court erred by denying Defendant’s motion to suppress. View "State v. Lar" on Justia Law

The Supreme Court affirmed the circuit court order, entered after a hearing, summoning William Joseph Wilkie to appear and testify in an out-of-state criminal proceeding in Clay County, Minnesota but reversed and remanded the order summoning Wilkie’s granddaughter, M.M.W., to appear and testify in the same criminal proceeding.In this consolidated appeal, Wilkie and M.M.W. argued that their rights as victims in the criminal proceeding were violated because they were not advised of their right to counsel during the circuit court hearing. The Supreme Court affirmed in part and reversed and remanded in part holding (1) because the proceedings in South Dakota did not implicate S.D. Const. art. VI, section 29, the circuit court had no obligation to advise either Wilkie or M.M.W. of any rights under Marsy’s Law; but (2) while the circuit court did not err in finding that Wilkie failed to present any evidence of hardship for himself in ordering Wilkie to appear and testify in Minnesota, the circuit court failed to make adequate findings on M.M.W.’s claim of hardship. View "In re Issuance of a Summons Compelling an Essential Witness to Appear & Testify" on Justia Law

The Supreme Court affirmed the circuit court order, entered after a hearing, summoning William Joseph Wilkie to appear and testify in an out-of-state criminal proceeding in Clay County, Minnesota but reversed and remanded the order summoning Wilkie’s granddaughter, M.M.W., to appear and testify in the same criminal proceeding.In this consolidated appeal, Wilkie and M.M.W. argued that their rights as victims in the criminal proceeding were violated because they were not advised of their right to counsel during the circuit court hearing. The Supreme Court affirmed in part and reversed and remanded in part holding (1) because the proceedings in South Dakota did not implicate S.D. Const. art. VI, section 29, the circuit court had no obligation to advise either Wilkie or M.M.W. of any rights under Marsy’s Law; but (2) while the circuit court did not err in finding that Wilkie failed to present any evidence of hardship for himself in ordering Wilkie to appear and testify in Minnesota, the circuit court failed to make adequate findings on M.M.W.’s claim of hardship. View "In re Issuance of a Summons Compelling an Essential Witness to Appear & Testify" on Justia Law

The Supreme Court affirmed Defendant’s convictions for first-degree murder, first-degree burglary, and second-degree rape, holding that the circuit court did not commit prejudicial error in any of the issues raised by Defendant.On appeal, Defendant argued that the circuit court committed several errors in its evidentiary rulings, erred by denying Defendant’s motions for mistrial, erred in denying Defendant’s proposed jury instructions, and erred by denying Defendant’s motion for judgment of acquittal. Defendant further argued that the accumulation of the errors constituted reversible error. The Supreme Court disagreed, holding that there was no prejudicial error. View "State v. Kryger" on Justia Law