Justia Criminal Law Opinion Summaries

Defendant was arrested and charged with driving under the influence after police officers approached a parked vehicle and found Defendant in the driver’s seat and smelled the odor of alcohol. Defendant filed a motion to suppress, asserting that the officer did not have reasonable suspicion to support the intrusion. The circuit court denied the motion to suppress, holding that the officer’s investigation was justified under the community caretaker exception to the warrant requirement. The Supreme Court affirmed, holding that the circuit court did not err when it concluded that the community caretaker exception to the warrant requirement applied and thus denied Defendant’s motion to suppress. View "State v. Kleven" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated assault. Defendant was sentenced to twenty years in the state penitentiary. Defendant appealed, arguing that the trial court erred by allowing a nurse practitioner who helped care for the victim to give her opinion regarding the seriousness of the victim’s injuries. The Supreme Court affirmed, holding that the circuit court did not err, let alone commit plain error, in permitting the nurse practitioner to opine whether the victim suffered a serious bodily injury, and therefore, Defendant was not deprived of a fair trial by jury. View "State v. Greenwood" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The circuit court sentenced Defendant to life imprisonment without parole. Defendant appealed, challenging the circuit court’s denial of his motion to suppress. Specifically, Defendant argued that the court erred when it found that exceptions to the warrant requirement existed and erred by failing to suppress his statements made to law enforcement prior to receiving Miranda warnings. The Supreme Court affirmed, holding (1) exigent circumstances existed justifying the officers’ warrantless entry of Defendant’s apartment; and (2) the admission of Defendant’s statements that he made to law enforcement before he received Miranda warnings was proper. View "State v. Rogers" on Justia Law

In 2007, Appellant pleaded guilty to two counts of possession of child pornography and admitted that he was a habitual offender. Appellant did not directly appeal his conviction. Nearly seven years after his conviction became final, Appellant filed a petition for a writ of habeas corpus, alleging multiple claims of ineffective assistance of counsel and a Miranda violation. After a hearing, the habeas court concluded that Appellant’s habeas petition was untimely and granted the State’s motion for summary judgment, dismissing Appellant’s petition with prejudice. The Supreme Court reversed, holding (1) the habeas court did not err in applying S.D. Codified Laws 21-27-3.3 to Appellant’s action because Appellant commenced the action after the effective date of the statute; but (2) in applying section 21-27-3.3, the habeas court had the authority to delay commencement of the two-year limitations period until the effective date of the statute, and because Appellant filed the action within the two years, the habeas court erroneously granted summary judgment against Appellant for violating the statute of limitations in section 21-27-3.3. View "Hughbanks v. Dooley" on Justia Law

Defendant was indicted with one count of second-degree rape. During his trial, Defendant requested access to summaries written by the prosecutor or by others in the prosecutor’s office documenting the victim’s oral declarations about the alleged rape, claiming that the notes were discoverable under S.D. Codified Laws 23A-13-10(4). The trial court concluded that the prosecutor’s notes were protected attorney work product and did not fall under section 23A-13-10. The jury subsequently found Defendant guilty of rape. The Supreme Court reversed, holding that Defendant was entitled to have notes in the possession of the prosecutor containing summaries of the victim’s prior statements related to the allegations against Defendant produced for an in camera review by the circuit court to determine if those notes contain statements discoverable under section 23A-13-10(4). If the court concludes that the notes contain discoverable statements under section 23A-13-10 that could have affected the outcome of the trial, the court is directed to vacate Defendant’s conviction and order a new trial. View "State v. Horned Eagle" on Justia Law

Defendant pleaded guilty to possession of a controlled substance, a Class 5 felony, and admitted the allegations of a habitual criminal information alleging that she had two prior felony convictions. Because of Defendant’s prior convictions, the circuit court imposed a Class 4 felony penitentiary sentence. The court did not state on the record any aggravating circumstances justifying a departure from presumptive probation. Defendant appealed, arguing that the circuit court erred in failing to sentence her to probation pursuant to the presumptive probation requirements. The Supreme Court reversed and remanded for sentencing, holding that the circuit court erred when it failed to state the aggravating circumstances on the record or in the judgment. View "State v. Flowers" on Justia Law

Defendant was stopped by a police officer because his vehicle’s left brake light was not working. Defendant was subsequently arrested for driving under the influence of alcohol. Defendant filed a motion to suppress. The circuit court granted the motion, concluding (1) since the relevant statute required only two working brake lights Defendant did not violate the law because his vehicle’s right and top-center brake lights were working; and (2) the officer’s belief that South Dakota law required a working left and right brake light was objectively unreasonable. The Supreme Court reversed, holding (1) the most reasonable interpretation of the pertinent statute is that the Legislature intended the display and actuation requirements to apply only to two brake lights; but (2) it was objectively reasonable for an officer to believe that Defendant’s inoperative left brake light constituted a violation of law. View "State v. Lerma" on Justia Law

After a jury trial, Defendant was convicted of sexual contact with a child under sixteen years of age. Defendant appealed, arguing that there was insufficient evidence to support his conviction and that the prosecutor committed misconduct by making a misstatement of law during closing arguments. The Supreme Court affirmed, holding (1) Defendant’s act of pressing his erect penis against the victim's buttocks constituted sexual contact and, as a result, a violation of S.D. Codified Laws 22-22-7, and thus, the circuit court did not err in denying Defendant’s motion for judgment of acquittal; and (2) the prosecutor’s closing argument was not erroneous and did not constitute prosecutorial misconduct. View "State v. Bariteau" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to a charge of unauthorized ingestion of a controlled substance. At the change of plea hearing, the State agreed to recommend a light sentence with no jail time. At sentencing, however, the State impliedly argued for a harsher sentence. The circuit court sentenced Defendant to five years of imprisonment with one year suspended. The Supreme Court vacated Defendant’s sentence and remanded for resentencing, holding that the State’s failure to recommend a light sentence and no jail time at sentencing was a material and substantial breach of the plea agreement. View "State v. Slotsky" on Justia Law

Defendant was charged with three counts of simple assault against a law enforcement officer, among other offenses. Defendant served a subpoena on the county sheriff requesting all disciplinary records and complaints contained within the arresting officer’s personnel file. The sheriff filed a motion to quash the subpoena. The circuit court denied the motion in part and ordered the sheriff to produce, for in camera review, portions of the officer’s personnel records from the past five years. The Supreme Court reversed, holding that the circuit court erred in ordering the sheriff to produce the arresting officer’s personnel records for in camera review. View "State v. Smith" on Justia Law