Justia Criminal Law Opinion Summaries

Defendant was charged with two 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 personnel files of three sheriff department detectives. The sheriff moved to quash the subpoena. The circuit court denied the motion in part and ordered the sheriff to produce, for in camera review, complaints against the officers and disciplinary records and actions resulting from the incident for which Defendant was charged. The Supreme Court reversed, holding that the circuit court erred in ordering the sheriff to produce portions of the three detectives’ personnel records for in camera review. View "State v. Johnson" on Justia Law

Defendant pleaded guilty to first-degree burglary. The circuit court sentenced Defendant to twenty years in prison with four years suspended and credit for time served. Defendant appealed, alleging that he received ineffective assistance of counsel, that the circuit court erred in denying his request for a new trial, and that his sentence constituted cruel and unusual punishment. The Supreme Court reversed, holding that the circuit court erred when it did not address Defendant’s motion for a change of counsel. Remanded for the circuit court to appoint new counsel and conduct a new sentencing hearing. View "State v. Martinez" on Justia Law

A jury convicted Cleve Janis, Jr. of third-degree rape in 2015. Janis appealed, arguing that the circuit court erred when it admitted undisclosed expert testimony. Janis also argued that the prosecutor committed misconduct through various statements during trial and that there was improper contact between a juror and a spectator. Finding no reversible error, the Supreme Court affirmed. View "South Dakota v. Janis" on Justia Law

Appellant pleaded guilty to simple assault. Appellant was sentenced to two years in the penitentiary - the maximum penalty - with no credit for time served. Appellant appealed, challenging the circuit court’s failure to give credit for time served and the constitutionality of his sentence. The Supreme Court affirmed, holding (1) the circuit court erred in failing to give credit for time served; and (2) Appellant’s sentence was not grossly disproportionate to the crime of simple assault and was thus constitutional under the Eighth Amendment. Remanded for correction of Appellant’s sentence to give credit for time served. View "State v. Ainsworth" on Justia Law

After a jury trial, Defendant was convicted of simple assault. Defendant appealed, arguing that the prosecutor’s reference to Defendant’s attorney in cross-examination and closing argument violated his Sixth Amendment right to counsel and deprived him of a fair trial. The Supreme Court affirmed Defendant’s convictions, holding (1) under the circumstances of this case, the prosecutor’s statements improperly suggested to the jury that Defendant and his defense counsel concocted a false defense to avoid a guilty verdict; but (2) a new trial was not warranted because Defendant was not prejudiced. View "State v. Pursley" on Justia Law

Appellant pleaded guilty to aggravated assault against a law enforcement officer. Appellant was sentenced to twenty-two years in prison. Appellant later filed a petition for writ of habeas corpus, arguing that his trial counsel provided constitutionally ineffective assistance and that his sentence was cruel and unusual punishment under the Eighth Amendment. After a hearing, the circuit court denied habeas relief. The Supreme Court affirmed, holding (1) Appellant did not receive ineffective assistance of counsel regarding his right to appeal and his right to remain silent during the presentence investigation; and (2) Appellant’s sentence was not unconstitutionally cruel or unusual. View "Stark v. Weber" on Justia Law

Appellant was convicted of possession of child pornography. The conviction was affirmed on direct appeal. Appellant later filed a pro se application for a writ of habeas corpus claiming that his jury trial was closed to the public in violation of his Sixth Amendment rights and that defense counsel’s failure to object to the closure constituted ineffective assistance of counsel. The habeas court dismissed Appellant’s application without holding an evidentiary hearing. The Supreme Court affirmed, holding that Appellant’s allegation of a Sixth Amendment public-trial violation failed to meet the “minimum threshold of plausibility.” View "Riley v. Young" on Justia Law

After a jury trial, Defendant was found guilty of second-degree murder and aggravated assault. The Supreme Court affirmed, holding (1) the trial court’s decision to instruct the jury on second-degree murder did not deprive Defendant of his constitutional right to notice of the charges against him and his right to defend against such charges where second-degree murder was not charged in the indictment; (2) the circuit court did not deny Defendant his right to confront witnesses by limiting his cross-examination of a State witness; (3) the circuit court did not err in refusing to suppress Defendant’s statements made to an officer immediately after the shooting; and (4) Defendant’s sentence for aggravated assault was not cruel and unusual in violation of the Eighth Amendment. View "State v. McCahren" on Justia Law

After a jury trial, Defendant was convicted of second-degree kidnapping and criminal trespass. Defendant appealed, arguing that the trial court erred in declining to give Defendant’s proposed instructions defining specific intent and voluntary intoxication. The Supreme Court reversed the conviction, holding (1) second-degree kidnapping is a specific intent crime, and the trial court abused its discretion by not so instructing the jury; (2) the trial court abused its discretion by denying Defendant’s proposed jury instruction related to voluntary intoxication so that the jury could properly consider his defense; and (3) Defendant was prejudiced by the trial court’s abuse of discretion. Remanded. View "State v. Liaw" on Justia Law

Defendant pleaded guilty to forgery. The circuit court accepted the plea after determining that a factual basis existed for the plea. The court sentenced Defendant without objection. Defendant appealed, arguing that the circuit court failed to obtain a factual basis that the offense occurred in South Dakota and that the adequacy of a factual basis for a plea is a jurisdictional issue. The Supreme Court affirmed, holding that an inadequate factual basis does not deprive a circuit court of its subject matter jurisdiction, and therefore, the circuit court had subject matter jurisdiction to adjudicate the case. View "State v. Sanders" on Justia Law