Justia Criminal Law Opinion Summaries

Twin brothers Ryan Alan Krause and Brian Michael Krause pleaded guilty to separate complaints alleging grand theft and four counts of unlawfully using a computer. The circuit court sentenced each of the Krauses to four years imprisonment for grand theft and two years imprisonment for each count of unlawfully using a computer system, and ordered all sentences to run consecutively. The Supreme Court affirmed, holding (1) the Krauses’ consecutive sentences for unlawfully using a computer system do not violate the Eighth Amendment’s prohibition against cruel and unusual punishment; and (2) the circuit court did not err by imposing sentences of imprisonment instead of probation for the unlawful-use-of-computer-system convictions. View "State v. Krause" on Justia Law

Defendant was convicted of driving under the influence. Defendant appealed, arguing that the trial court erred in denying his motion to suppress evidence resulting from a traffic stop, including the results of a blood test, arguing that the arresting officer lacked reasonable suspicion to conclude that Defendant had committed a crime in order to justify the traffic stop. The Supreme Court reversed, holding that the circuit court erred in denying Defendant’s motion to suppress because the arresting officer did not have a reasonable suspicion of criminal activity, and any evidence resulting from the stop was the product of an illegal search. View "State v. Stanage" on Justia Law

Defendant was convicted of first-degree murder and received a mandatory sentence of life in prison. Defendant was fourteen years old when he committed the offense. After the United States Supreme Court issued Miller v. Alabama, which barred mandatory life sentences against juvenile homicide offenders, Defendant filed a motion to have his sentence correct. After a hearing, the sentencing court resentenced Defendant to ninety-two years in prison. The Supreme Court affirmed, holding (1) a ninety-two-year sentence is not categorically unconstitutional for a fourteen-year-old child; (2) because Defendant had the opportunity for release at age sixty, his sentence was not the legal equivalent of a life sentence without parole; (3) the sentencing court properly considered the mitigating qualities of youth set forth in Miller; (4) Defendant’s sentence was not grossly disproportionate to the gravity of the offense; and (5) the sentencing court did not commit prejudicial error when it permitted an oral victim-impact statement by an individual outside the statutory definition of a victim. View "State v. Charles" on Justia Law

Sueellan Kline and her boyfriend, Douglas Strong, a parolee, lived together in a motel room. Parole agent Connie Johnson went to the motel room to obtain a urine sample from Strong. When Strong’s urine field-tested positive to methamphetamine Johnson removed Strong from the room and detained him in the hallway. Johnson then reentered the room and asked Kline if there were drugs or drug paraphernalia in the room. In response, Kline removed a methamphetamine pipe from her purse and handed it to Johnson. The pipe was used to obtain a search warrant for Kline’s urine, which tested positive for methamphetamine and amphetamine. Kline filed a motion to suppress the evidence, arguing that it was obtained as the result of an illegal search. The circuit court denied the motion. Kline was subsequently convicted of ingestion of a controlled substance. The Supreme Court affirmed, holding that Johnson lawfully reentered the residence and that Kline voluntarily consented to production of the methamphetamine pipe, and therefore, the evidence was not obtained in violation of the Fourth Amendment. View "State v. Kline" on Justia Law

Defendant pleaded guilty to one count of possessing a controlled substance. The circuit court departed from a presumptive sentence of probation and sentenced Defendant to four years in prison. Defendant appealed, arguing that the circumstances enumerated by the circuit court did not justify a departure from the presumptive sentence of probation, as the court failed to identify aggravating factors sufficient to deviate from a presumptive sentence of probation. The Supreme Court affirmed, holding that Defendant’s criminal history and complete disregard for supervised release indicated that the circuit court’s departure from the presumptive sentence of probation was warranted. View "State v. Underwood" on Justia Law

After a jury trial, Defendant was convicted of four counts of rape in the first degree and two counts of sexual contact with a child under sixteen years of age. The Supreme Court affirmed in part and reversed in part, holding (1) the circuit court did not abuse its discretion in limiting cross-examination to exclude statements regarding self-harm; (2) the circuit court erred in denying a judgment of acquittal on the two sexual contact counts; (3) the State offered sufficient evidence to convict Defendant; and (4) the circuit court did not impose a cruel and unusual punishment in violation of the Eighth Amendment and did not abuse its discretion in sentencing Defendant. Remanded. View "State v. Bausch" on Justia Law

After a jury trial, Defendant was found guilty of first-degree manslaughter, commission of a felony with a firearm, and possession of a controlled weapon. Defendant appealed, arguing, inter alia, that the State committed a violation of Brady v. Maryland when it denied Defendant access to certain records. The Supreme Court issued a limited remand to determine whether a Brady violation occurred in this case and to include the records in the record. On remand, the circuit court concluded that the State committed no Brady violation as it pertained to the challenged records. The Supreme Court affirmed, holding (1) the circuit court did not err when it concluded that the State committed no Brady violation; and (2) the circuit court did not err in determining that Defendant was not entitled to a new trial related to the subject records. View "State v. Birdshead" on Justia Law

Defendant pleaded guilty to one count of aggravated incest and four counts of abusing his children. Defendant was sentenced to a total of forty-seven years imprisonment and ordered to pay the Department of Social Services $19,555 for counseling and treatment costs incurred in caring for the children. Defendant appealed from the reimbursement order, contending that the Department was not statutorily entitled to the reimbursement order because it was not a victim of Defendant’s crimes. The Supreme Court affirmed, holding that, even if the Department did not qualify as a victim under S.D. Codified Laws 23A-28-2(5), Defendant was still responsible for paying the entirety of his victims’ treatment costs under S.D. Codified Laws 23A-28-12. View "State v. Jones" on Justia Law

Defendant was charged with murder and kidnapping. Defendant was a juvenile at the time of the crime. The State moved to transfer Defendant’s case to adult court. After a hearing, the juvenile court granted the State’s motion to transfer. After a trial in adult court, the jury found Defendant guilty of first-degree murder (arson), first-degree felony murder, first-degree arson, felony murder (aggravated kidnapping), and second-degree aggravated kidnapping. Defendant was sentenced to eighty years imprisonment for the murder conviction and a concurrent fifty-year sentence for second-degree aggravated kidnapping. The Supreme Court affirmed, holding (1) the juvenile court did not err in transferring Defendant to adult court; (2) the circuit court did not fail to adequately instruct the jury on Defendant’s theory of defense; and (3) Defendant’s eighty-year-sentence was not an abuse of discretion, grossly disproportionate, or a de facto life sentence in violation of the spirit of Montgomery v. Louisiana. View "State v. Diaz" on Justia Law

Defendant was indicted for eight drug-related offenses. After a jury trial, Defendant was convicted of seven of the eight counts. Defendant appealed, arguing (1) the trial court erred by amending the indictment the day before trial, and (2) the trial court committed plain error by not informing the parties of a jury question that arose during deliberations and then by answering that question without input from the parties. The Supreme Court affirmed, holding (1) the trial court did not commit plain error by amending the indictment the day prior to trial; and (2) the trial court did not commit plain error by not notifying the parties of the jury’s question at the time it occurred. View "State v. Schrempp" on Justia Law