Justia Criminal Law Opinion Summaries

The Supreme Court reversed the circuit court’s order rejecting the plea agreement between Defendant and the State.After Defendant and the State entered into a plea agreement the circuit court accepted Defendant’s guilty plea and the factual basis to support the plea. Two weeks later, the circuit court informed the parties that it intended to reject the plea agreement. The court then entered an order rejecting the plea agreement. Defendant appealed, arguing that the circuit court was bound by the plea agreement. The Supreme Court agreed, holding that because the circuit court at the time of the plea did not reject the agreement and did not defer its decision to accept or reject the agreement, the circuit court was required to sentence Defendant within the bounds of the plea agreement. The court remanded the case with directions to sentence Defendant in accordance with the agreement. View "State v. Hale" on Justia Law

The Supreme Court reversed the circuit court’s order rejecting the plea agreement between Defendant and the State.After Defendant and the State entered into a plea agreement the circuit court accepted Defendant’s guilty plea and the factual basis to support the plea. Two weeks later, the circuit court informed the parties that it intended to reject the plea agreement. The court then entered an order rejecting the plea agreement. Defendant appealed, arguing that the circuit court was bound by the plea agreement. The Supreme Court agreed, holding that because the circuit court at the time of the plea did not reject the agreement and did not defer its decision to accept or reject the agreement, the circuit court was required to sentence Defendant within the bounds of the plea agreement. The court remanded the case with directions to sentence Defendant in accordance with the agreement. View "State v. Hale" on Justia Law

The Supreme Court affirmed the judgment of the circuit court, rendered after a jury trial, convicting Defendant of aggravated assault (domestic) and simple assault (domestic). On appeal, Defendant challenged the circuit court’s admission of evidence of alleged instances of prior domestic abuse and claimed that his trial counsel was constitutionally ineffective. The Supreme Court held (1) the circuit court did not err in admitting the other acts evidence; and (2) counsel was not so ineffective that it deprived Defendant of his constitutional rights to counsel and a fair trial. View "State v. Phillips" on Justia Law

In 2016, Berton Toavs shot and killed his girlfriend Eliza Edgins and his friend Nathan Gann at Toavs’s home in Faith, South Dakota. Toavs and Edgins were in an off-and-on romantic relationship for some time, and Gann had been staying at Toavs’s home for approximately six weeks prior to the incident. During the time Gann had been staying with Toavs, a romantic relationship developed between Edgins and Gann. Gann and Edgins apparently planned to leave South Dakota and continue their relationship. After hearing this news, Toavs left the house, returning the following morning. Toavs and Edgins argued, ending with Toavs going to his bedroom, grabbing his .45 caliber Colt revolver, and shooting Edgins multiple times. He then shot Gann, who had been sleeping on the living room floor. Both Edgins and Gann died from the gunshot wounds. Toavs appeals his sentences issued on two counts of first-degree manslaughter, arguing the sentencing court abused its discretion in ordering him to serve two consecutive sentences of 110 and 100 years. According to Toavs, the sentencing court did not adequately consider whether Toavs was capable of rehabilitation prior to imposing the sentences. Finding no reversible error, the South Dakota Supreme Court affirmed Toavs’s sentences. View "South Dakota v. Toavs" on Justia Law

Clint Bolton was charged with alternative counts of simple assault, a class 1 misdemeanor. Pursuant to a plea agreement, the State filed an amended complaint charging disorderly conduct, a class 2 misdemeanor. Class 2 misdemeanors carry a maximum sentence of thirty days in jail or a $500 fine or both. The State also agreed to recommend a thirty-day jail sentence with all thirty days suspended. Bolton agreed to the plea agreement, and counsel entered a no contest plea to disorderly conduct on Bolton’s behalf. The magistrate court accepted the plea and imposed a thirty-day jail sentence. The court then suspended execution of that sentence on the condition that Bolton obey all laws and remain on good behavior for six months. Bolton’s attorney immediately objected to the sentence, arguing the court could not condition a suspended execution of sentence for a period longer than thirty days, the statutory maximum term of imprisonment for class 2 misdemeanors. The issue before the South Dakota Supreme Court was whether sentencing courts have the power to suspend execution of sentence on the condition of good behavior for periods longer than the authorized maximum term of imprisonment. The Court concluded sentencing courts indeed have such power because it has been delegated to them by the Constitution and the Legislature has not restricted it. View "South Dakota v. Bolton" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant’s motion for a new trial.In State v. Bausch, the Supreme Court reversed Defendant’s convictions for sexual contact and remanded the case with direction that the circuit court vacate the convictions and resentence Defendant on his four rape convictions. On remand, the circuit court vacated Defendant’s sexual contact convictions and resentenced Defendant on the four rape convictions. Defendant filed a motion for a new trial, which the circuit court denied. The Supreme Court affirmed, holding that the circuit court carried out this court’s remand directive when it vacated Defendant’s sexual contact convictions and resentenced Defendant on the four rape convictions. View "State v. Bausch" on Justia Law

The Supreme Court affirmed the sentence imposed upon Defendant to a five-year penitentiary term while Defendant was serving a probationary sentence imposed in a different criminal file. On appeal, Defendant argued that the sentencing court imposed an illegal sentence when it placed him under the dual supervision of the judicial and executive branches. The Supreme Court held (1) the sentencing court erred when it placed Defendant under simultaneous supervision of two branches of government; but (2) because Defendant was currently only under the supervision of the executive branch, the sentence was constitutional. View "State v. Humpal" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of threatening a judicial officer and disorderly conduct arising from statements Defendant made in the Minnehaha County Courthouse. At the conclusion of a court trial, the circuit court ruled that Defendant’s statements were “true threats” rather than speech protected by the First Amendment. Defendant appealed, arguing that his statements were protected speech and therefore could not be the basis for criminal conduct. The Supreme Court disagreed, holding that Defendant’s statements at the courthouse were not protected speech but, rather, constituted true threats under the relevant factors. View "State v. Draskovich" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree murder and sentencing him to mandatory life in prison. The court held (1) the circuit court did not err in its evidentiary rulings that Defendant consented to the seizure of his property from the hospital and that the revocation of that consent did not require the return of his property; (2) the circuit court did not err in denying Defendant’s motion to suppress evidence seized at Defendant’s friend’s house; (3) the circuit court did not abuse its discretion when it admitted twenty-six autopsy photographs during the trial; (4) the circuit court did not err in denying Defendant’s motion for a new trial on his claim of improper burden shifting; and (5) the evidence was sufficient to support Defendant’s conviction. View "State v. Hemminger" on Justia Law

The Supreme Court affirmed the habeas court’s denial of Appellant’s petition for habeas corpus relief.Appellant pleaded guilty but mentally ill to first-degree manslaughter and to second-degree rape. The circuit court imposed a 130-year sentence for first-degree manslaughter and a forty-five-year sentence for second-degree rape. The Supreme Court affirmed on appeal. Thereafter, Appellant filed a petition for habeas relief, arguing, inter alia, that he was deprived of effective assistance of counsel and was compelled to give testimony against himself where the court ordered a psychological examination and where his attorney failed to warn Appellant that statements made to the examiner could be used against him. The habeas court denied Appellant’s petition. The Supreme Court affirmed, holding (1) Appellant waived his Fifth Amendment right against self-incrimination by failing to invoke it during the psychological examination, and Appellant was not deprived of effective assistance of counsel; and (2) Appellant was not deprived of due process, nor was his counsel ineffective for failing to request a hearing to determine if Appellant should receive provisional institutionalization under S.D. Codified Laws 23A-27-42 View "Iannarelli v. Young" on Justia Law