Justia Criminal Law Opinion Summaries

Defendant pleaded guilty in a South Dakota circuit court to driving under the influence and admitted to being a habitual offender. The magistrate court did not specifically inform Defendant that a guilty plea would impact his Nebraska commercial driver’s license (CDL). A year after the judgment of conviction was entered Defendant filed a motion to reopen his case and allow him to withdraw his guilty plea under S.D. Codified Laws 23A-27-11, claiming that the loss of his CDL constituted a manifest injustice. The circuit court denied Defendant’s motion. The Supreme Court dismissed Defendant’s appeal, holding that the Court did not have jurisdiction to consider the appeal because Defendant’s motion under section 23A-27-11 was not filed more than thirty days after entry of the judgment of conviction. View "State v. Kaufman" on Justia Law

Defendant was convicted of driving under the influence and having an open container of alcohol in a motor vehicle. Defendant appealed, arguing that the magistrate court and circuit court erred by failing to suppress evidence from the traffic stop that led to his convictions because the law enforcement officer lacked reasonable suspicion to initiate the traffic stop. The Supreme Court affirmed, holding that the totality of the circumstances led to a reasonable suspicion of criminal activity, and therefore, the lower courts did not err in denying Defendant’s motion to suppress. View "State v. Olson" on Justia Law

After a jury trial, Defendant was found guilty of six counts of kidnapping in the first degree, eleven counts of aggravated assault, possession of methamphetamine, and possession of methamphetamine with intent to distribute. The Supreme Court affirmed, holding (1) there was sufficient evidence to convict on the kidnapping charges; (2) the circuit court did not err in refusing to give Defendant’s proposed jury instruction on kidnapping; (3) Defendant’s challenge to the sufficiency of the evidence on the remaining charges was waived for consideration on appeal; and (4) the circuit court’s sentence did not violate the Eighth Amendment’s prohibition against cruel and unusual punishment. View "State v. Traversie" on Justia Law

Appellant pleaded guilty to first-degree murder. Appellant was sentenced to eighty years’ imprisonment and ordered to reimburse the county for costs of prosecution. Appellant later filed a petition for writ of habeas corpus, raising six issues for review. The circuit court denied the claims after an evidentiary trial. Appellant appealed, raising three issues for review. The Supreme Court affirmed, holding (1) Appellant failed to prove that his trial counsel’s performance was deficient or that Appellant was prejudiced; (2) the State did not violate the terms of the plea-bargain agreement; and (3) the sentencing court did not err by failing to advise Appellant of his Boykin rights during sentencing. View "Keinsasser v. Weber" on Justia Law

Defendant pleaded guilty to first-degree manslaughter and was sentenced to eighty years’ imprisonment with twenty years suspended. Defendant appealed, arguing that his sentence violates the Eighth Amendment’s prohibition against cruel and unusual punishment. Specifically, Defendant argued that his sentence was cruel and unusual because it was disproportionate to the sentence that his codefendant received for the same offense. The Supreme Court affirmed, holding (1) the harshness of Defendant’s sentence is not grossly disproportionate to the gravity of his offense, and although his sentence is more severe than his codefendant’s, his culpability is correspondingly greater; and (2) therefore, the circuit court did not violate the Eighth Amendment or abuse its discretion in sentencing Defendant. View "State v. Rice" on Justia Law

After a jury trial, Defendant was convicted of fourth-degree rape. The Supreme Court affirmed on appeal, holding (1) because the record was insufficient to allow for an appropriate review of Defendant’s argument that his trial counsel provided ineffective assistance because she did not understand S.D. Codified Laws 19-19-412; (2) the circuit court did not commit prejudicial error when it concluded that Defendant was not entitled to a hearing under section 19-19-412 because he did not file a motion for a hearing fourteen days before trial; (3) the circuit court did not abuse its discretion when it limited Defendant’s cross-examination of the victim to questions related to the victim’s sexual encounters with Defendant; and (4) the circuit court did not err when it considered Defendant’s juvenile psychological records to determine an appropriate sentence. View "State v. Golliher-Weyer" on Justia Law

Defendant was convicted of simple assault. Defendant appealed, arguing that the circuit court (1) erred in refusing to give a definitive ruling, at the close of the State’s evidence, on his request for a self-defense jury instruction; and (2) violated his constitutional right of confrontation by admitting certified copies of his fingerprint cards from prior arrests in Iowa and Nebraska. The Supreme Court affirmed, holding (1) the circuit court did not err in the manner in which it instructed on self-defense; and (2) the admission of fingerprint cards does not violate the Confrontation Clause because they are not testimonial. View "State v. Reinhardt" on Justia Law

Defendant was convicted of vehicular homicide, driving with alcohol in his blood or while under the influence of alcohol or drugs, possession of marijuana, and ingesting a non-alcoholic substance to become intoxicated. Defendant appealed, arguing that the trial court erred when in denying his motion to suppress a blood draw because law enforcement and hospital personnel took blood samples from him in violation of his constitutional rights. The Supreme Court affirmed, holding (1) blood drawn by hospital personnel for medical purposes is not subject to Fourth Amendment protection, and therefore, suppression of the draw was not warranted; and (2) exigent circumstances existed in regard to the warrantless blood draw ordered by law enforcement such that the blood draw was objectively reasonable. View "State v. Fischer" on Justia Law

After a jury trial, Defendant was convicted of six counts of child rape and six counts of sexual contact with a minor. The Supreme Court affirmed, holding (1) the evidence was sufficient to show six sexual penetrations; (2) the evidence was sufficient and to establish the county where three of the child rape counts occurred; and (3) the counts within the indictment that were identically phrased did not deprive Defendant of fair notice and the ability to defend against double jeopardy, and the record did not support a finding that the jury punished Defendant twice for one crime. View "State v. Hernandez" on Justia Law

After a jury trial, Defendant was convicted of one count of second-degree burglary and four counts of identity theft. Defendant subsequently pleaded guilty but mentally ill to grand theft. Defendant appealed, challenging both his jury convictions and the sentences imposed for each of his crimes. The Supreme Court affirmed, holding (1) the performance of defense counsel did not clearly deprive Defendant of his constitutional rights to counsel and a fair trial; (2) Defendant’s sentence did not violate the Eighth Amendment’s prohibition against cruel and unusual punishment; and (3) the circuit court did not err by denying Defendant’s motion for judgment of acquittal on the charges of second-degree burglary and identity theft. View "State v. Chipps" on Justia Law