Justia Criminal Law Opinion Summaries

Defendant pleaded guilty to simple assault and aggravated assault. For aggravated assault, Defendant was sentenced to a thirteen-year penitentiary sentence, suspended on certain conditions. One of the conditions was that Defendant consent to any treatment plan deemed necessary by his Court Services Officer (CSO). Defendant’s CSO told Defendant that he must undergo a sex offender evaluation. The circuit court later revoked Defendant’s suspended sentence for failure to obtain a sex offender evaluation. The Supreme Court reversed, holding that the circuit court erred when it unlawfully delegated its judicial authority to a CSO to create and impose a condition of probation for a sex offender evaluation and treatment. Accordingly, the court erred when it revoked Defendant’s suspended sentence. Remanded. View "State v. Blakney" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of first degree rape, sexual contact with a child under the age of sixteen, and aggravated incest based on allegations that Defendant had sexually abused his nine-year-old granddaughter. The Supreme Court affirmed the convictions, holding (1) the circuit court did not abuse its discretion by prohibiting testimony as to the victim’s brother’s statements; (2) the circuit court did not abuse its discretion by allowing Defendant to proceed pro se at sentencing; (3) Defendant’s sentence did not constitute cruel and unusual punishment; and (4) Defendant’s arguments that he received effective assistance of counsel at trial were not ripe for review on direct appeal. View "State v. Craig" on Justia Law

Joseph Burkett was arrested by Officer Justin Lux after the officer approached the Burkett’s vehicle, which was stopped in the middle of the road, and concluded that Burkett had been driving under the influence. A jury found Burkett guilty of DUI. Based on Burkett’s two prior DUI convictions within ten years of the current offense, Burkett was sentenced to a Class 6 felony. The Supreme Court affirmed, holding (1) the circuit court’s use of Burkett’s prior DUI convictions for sentencing enhancement purposes did not violate Burkett’s right to due process; (2) there was sufficient evidence to support the jury’s verdict; and (3) the circuit court did not err in denying Burkett’s motion to suppress based on Officer's Lux’s stop of Burkett, as the officer's decision to stop Burkett was reasonable. View "State v. Burkett" on Justia Law

After a jury trial, Defendant was found guilty of aggravated assault. On appeal, Defendant argued that the State’s peremptory strike of a Native American veniremember was racially motivated. The Supreme Court held that the circuit court had failed to address third step of the Batson v. Kentucky analysis and remanded with directions for the court to determine whether Defendant satisfied his burden to prove the State’s peremptory strike was racially motivated. On remand, the circuit court performed the third step and concluded that the State’s strike was not based on purposeful racial discrimination. The Supreme Court affirmed after a de novo review, holding that Defendant failed to carry his burden of proving purposeful racial discrimination. View "State v. Scott" on Justia Law

Appellant was charged by information with driving under the influence (DUI). A supplemental information alleged that Appellant had been convicted of DUI in 2009. The State asserted that the prior DUI conviction enhanced the new charge to a second offense DUI. Appellant moved to strike the 2009 conviction on the grounds that it was not entered knowingly and voluntarily. The circuit denied Appellant’s motion to strike her predicate conviction, ruling that Appellant did not overcome the presumption of regularity that attached to her 2009 guilty plea. The Supreme Court affirmed, holding that the circuit court’s finding was not clearly erroneous. View "State v. Woodard" on Justia Law

After a jury trial, Defendant was found guilty of three counts of distribution of a controlled drug or substance and three counts of possession of a controlled drug or substance. The Supreme Court affirmed the convictions, holding that the circuit court (1) did not violate Defendant’s due process rights in denying his motion to suppress an in-court identification stemming from an improper photo lineup; (2) did not err in refusing Defendant’s proposed jury instruction regarding cross-racial identification; and (3) did not err in denying Defendant’s motion for judgment of acquittal, as there was sufficient evidence to support the jury verdict. View "State v. Chuol" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault, discharge of a firearm at a car, and possession of a firearm by a prohibited person. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion when it admitted evidence of Defendant’s 2002 conviction as other act evidence under S.D. R. Crim. P. 404(b), where the probative value of the evidence outweighed the potential for unfair prejudice; and (2) the State presented sufficient evidence to support the jury’s verdict finding Defendant guilty of aggravated assault. View "State v. Boe" on Justia Law

Defendant, who was fifteen years old and a native Spanish speaker, was transported to the police department for questioning in connection with the death of Jasmine Guevara. During her questioning by police, Defendant confessed to the murder. Defendant moved to suppress her confession, arguing that she did not voluntarily, knowingly, and intelligently waive her Miranda rights. The juvenile court denied the motion. The case was then transferred to adult court in the First Judicial Circuit. The trial court reopened the motion to suppress and granted the motion, concluding that Defendant made her statements voluntarily but did not knowingly and intelligently waive her rights. The State appealed. The Supreme Court reversed, holding that the trial court erred in suppressing Defendant’s confession where the State met its burden to show more likely than not that Defendant’s waiver of her Miranda rights was “with a full awareness of both the nature of the right being abandoned and the consequences of the decision to abandon it.” View "State v. Diaz" on Justia Law

In 2012, Defendant was charged with driving under the influence of alcohol (DUI). A part II information alleged that Defendant had three prior DUI convictions within the last ten years, in 2003, 2004, and 2007. Defendant moved to strike the prior convictions, alleging that he pleaded guilty to the DUI charges without being adequately advised of his Boykin rights, rendering the prior convictions invalid. The circuit court denied the motion. The Supreme Court reversed in part, holding that there was a complete absence of any Boykin waiver advisement in the 2007 case, and thus, the circuit court erred in denying Defendant’s motion to strike his 2007 conviction. Remanded for resentencing. View "State v. Bilben" on Justia Law

Defendant pleaded guilty to grand theft by insufficient funds check. Defendant was subsequently sentenced to eight years in the penitentiary. Defendant appealed, arguing that the trial judge failed properly to advise him of all of his constitutional and statutory rights at his plea hearing and that his sentence violated the Eighth Amendment. The Supreme Court affirmed, holding (1) Defendant knowingly and voluntarily entered his guilty plea; and (2) Defendant’s contention that his eight-year penitentiary sentence constituted cruel and unusual punishment was without merit. View "State v. King" on Justia Law