Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of aggravated grand theft by deception over $100,000 and sentenced to a term of twenty-five years. On appeal, Defendant argued that the trial court erred by refusing to grant his motion for judgment of acquittal, failing to instruct the jury regarding the defense of advice of counsel, and instructing the jury that it should consider Defendant’s flight as it related to consciousness of guilt. The Supreme Court reversed, holding that there was insufficient evidence to prove that Defendant obtained the “property of another” worth over $100,000, and consequently, the circuit court erred by not granting Defendant’s motion for a judgment of acquittal. View "State v. Thomason" on Justia Law

Pursuant to a plea agreement, Defendant pled guilty to fourth offense driving under the influence. During a sentencing hearing, the circuit court found the existence of aggravating circumstances and sentenced Defendant to five years in the state penitentiary with three years suspended. On appeal, Defendant argued that while the circuit court correctly acknowledged the applicability of S.D. Codified Laws 22-6-11 to his sentencing, it erred by failing to order probation. The Supreme Court affirmed Defendant’s conviction and sentence, holding that the circuit court complied with the dictates of section 22-6-11 when it imposed a sentence other than probation. View "State v. Hernandez" on Justia Law

In 2012, a grand jury indicted Defendant for a DUI offense and for obstructing a public officer. A Part II Information was subsequently filed alleging that Defendant had been convicted of two prior DUI offenses. Defendant moved to dismiss the 2012 Part II Information, arguing that the prior convictions were invalid for enhancement purposes because the magistrate judges’ failure to strictly follow procedure resulted in the magistrate courts’ failure to obtain subject matter jurisdiction over the actions. The circuit court denied the motion. In 2013, Defendant pleaded guilty to driving or control of a motor vehicle while having .08 percent or more by weight of alcohol in his blood, as charged in the 2012 indictment. The circuit court denied Defendant’s request to be granted a suspended imposition of sentence, ruling that he was ineligible pursuant to S.D. Codified Laws 23A-27-13. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Defendant’s motion to dismiss the Part II Information because the courts in Defendant’s predicate convictions assumed proper jurisdiction over the cases; and (2) the circuit court’s application of section 23A-27-13 did not violate the constitutional prohibition against ex post facto legislation. View "State v. Smith" on Justia Law

After a jury trial, Defendant was convicted of first-degree burglary and obstructing a law enforcement officer. The Supreme Court affirmed, holding (1) obstructing law enforcement is an appropriate predicate offense to support a charge of first-degree burglary; (2) the trial court did not err by allowing the State to exercise a peremptory strike, where Defendant failed to prove that the State’s use of its peremptory strike was racially motivated; and (3) the trial court did not abuse its discretion by excluding a letter written by Defendant to the victims of the burglary as hearsay evidence. View "State v. Hatchett" on Justia Law

Shannon Flowers filed an application for writ of habeas corpus, which the trial court denied. More than thirty days after the circuit court’s denial, Flowers filed a motion for issuance of certificate of probable cause. In spite of the untimeliness of his motion, the circuit court granted Flowers’s motion and certified an issue for appeal. The Supreme Court dismissed Flowers’s appeal, holding (1) Flowers’s motion for issuance of certificate of probable cause was late, and therefore, jurisdictionally defective; and (2) because the circuit court lacked jurisdiction, the Court also lacked jurisdiction to consider the issue certified on appeal. View "Flowers v. Weber" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to simple assault under S.D. Codified Laws 22-18-1(4). The caption of the information included the words “domestic abuse,” but Defendant did not challenge whether the assault involved domestic abuse. Additionally, Defendant’s attorney acknowledged that Defendant was pleading guilty to simple assault (domestic abuse). Defendant moved to withdraw his guilty plea, arguing that the charging information was insufficient and that he did not knowingly and voluntarily plead guilty to simple assault (domestic abuse). The magistrate court denied the motion. The circuit court affirmed. The Supreme Court affirmed, holding (1) any argument Defendant had regarding defects in the information was waived because it was not raised prior to Defendant’s guilty plea; and (2) Defendant understood his rights, and his plea was knowing and voluntary. View "State v. Outka" on Justia Law

A federal court issued an arrest warrant for Christopher Yellow Eagle, whose warrant was referred to a task force that included federal and county law enforcement officers. The task force officers learned Yellow Eagle was living with Defendant, who had an outstanding warrant for her arrest. The task force arrested Defendant and Yellow Eagle at Defendant’s home after observing that Defendant and Yellow Eagle appeared to be under the influence of a controlled substance and had drugs on their persons. After a court trial, Defendant was convicted of possession of a controlled substance and sentenced to four years incarceration with four years suspended. Defendant appealed the circuit court’s denial of her motion to suppress, arguing (1) the task force officers who executed the arrest warrant were not authorized to enter her home to arrest her, and (2) because Yellow Eagle was a third party in her home, the officers were required to obtain a separate search warrant for the home. The Supreme Court affirmed, holding that the task force officers constitutionally entered Defendant’s home to arrest Defendant, or alternatively, Yellow Eagle. View "State v. Quevedo" on Justia Law

After a jury trial, Defendant was found guilty of eight counts of making false or fraudulent sales tax returns. On appeal, Defendant argued that the circuit court erred in (1) denying his Batson challenges to three peremptory strikes exercised by the State because the court’s Batson analysis was incomplete; and (2) denying his motion for judgment of acquittal. The Supreme Court (1) held that because the Court was unable to determine under the record the circuit court’s reason for denying the Batson challenges, limited remand was required to allow the circuit court to engage in the missing analysis; and (2) affirmed the denial of Defendant’s motion for judgment of acquittal, as the evidence was sufficient to sustain the convictions. View "State v. Guthmiller" on Justia Law

In 2001, Plaintiff, a Honduran national, pleaded guilty to a felony in South Dakota and received a four-year suspended sentence. In 2013, Plaintiff filed a petition for a writ of error coram nobis seeking to vacate his 2001 conviction, asserting that the conviction was invalid because he pleaded guilty without being given Padilla and Boykin advisements. The circuit court granted the State’s motion for summary judgment. The Supreme Court affirmed, holding that because coram nobis was unavailable to remedy Plaintiff’s claimed Padilla and Boykin violations, the circuit court correctly granted summary judgment in favor of the State. View "Garcia v. State" on Justia Law

After a jury trial, Defendant was convicted of possessing and distributing synthetic marijuana. At trial, Defendant’s defense was that he mistakenly believed that the products had no illicit substances in them. On the question of knowledge, the State was required to prove Defendant’s awareness of the character and nature of the substances he was possessing and selling. On appeal, Defendant asserted that the trial court plainly erred when it gave the jury misleading and incomplete jury instructions on what was required to prove “knowing possession” of a controlled substance. The Supreme Court affirmed, holding (1) the circuit court adequately instructed the jury on the element of knowledge in the absence of a request for a more precise definition; and (2) the circuit court did not plainly err by not giving a mistake of fact instruction sua sponte. View "State v. Toben" on Justia Law