Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree burglary, aggravated assault, and grand theft, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held that the circuit court (1) did not commit plain error by allowing a police officer to testify that Defendant invoked his right to an attorney; (2) did not err by denying Defendant's motion for judgment of acquittal concerning the aggravated assault charge; and (3) did not err by denying Defendant's motion for judgment of acquittal concerning his aggravated assault and first-degree burglary charges. View "State v. Robertson" on Justia Law

The Supreme Court reversed the judgment of the circuit court's preliminary ruling that Appellant could provide testimony from an expert witness on the capacity of a ten-year-old alleged third-party perpetrator to have killed Appellant's daughter, A.H., holding that the circuit court abused its discretion.Appellant was arrested and charged by complaint with second-degree murder in connection with the death of her three-year-old daughter A.H. Appellant's theory at trial was that a ten-year-old boy inflicted the injuries upon A.H. that caused her death. At issue was the circuit court's grant of Appellant's motion to offer third-party perpetrator evidence at trial. The circuit court denied Appellant's request to admit direct evidence of the boy's other acts but allowed admission of the opinion testimony at issue. The Supreme Court reversed, holding that the circuit court erroneously applied Rule 404(a) and (b) and Rule 703 in allowing the admission of the proffered expert testimony. View "State v. Hernandez" on Justia Law

In a previous decision involving a reporter’s request for information concerning an investigation involving Sanford, the South Dakota Supreme Court held that SDCL 23A-35-4.1 permits a circuit court to “seal the contents of an affidavit in support of a search warrant upon a showing of reasonable cause, but only until the investigation is terminated or an indictment or information is filed.” The court may not prohibit the public disclosure of other specific records nor of the fact that a search warrant affidavit has been filed.” Certain personally identifying information within court records must be redacted as a matter of course.Following the completion of the state’s criminal investigation, the circuit court unsealed the search warrant affidavits related to the investigation. Sanford challenged the denial of his request to inspect and participate in redacting the affidavits before the records were unsealed. The South Dakota Supreme Court affirmed. The circuit court properly applied the provisions of SDCL 15-15A-13 and 23A-35-4.1 and thoroughly considered the statutory and constitutional grounds asserted by Sanford with respect to information that could conceivably be contained in the affidavits. The court appropriately exercised its discretion to “decide whether there [were] sufficient grounds to prohibit access” to the contents of the affidavits. View "Matter Of Implicated Individual" on Justia Law

The Supreme Court affirmed in part, reversed in part, and vacated Defendant's conviction of multiple offenses relating to the assault of his ex-wife and his later efforts to get the pending charges dismissed, holding that the circuit court erred in denying Defendant's motion for judgment of acquittal on the charge of engaging in threatening or harassing contact, in violation of S.D. Codified Laws 49-31-31(1).After a trial, Defendant was found guilty of six counts, including two counts of aggravated assault and threatening or harassing contact. The Supreme Court reversed in part, holding (1) the circuit court did not err by not granting Defendant's motions for judgment of acquittal on the charges of aggravated assault in violation of S.D. Codified Laws 22-18-1.1(1) and S.D. Codified Laws 22-18-1.1(5); but (2) there was insufficient evidence presented to the jury to support a finding of guilt on the charge of engaging in threatening or harassing contact in violation of S.D. Codified Laws 49-31-31(1). View "State v. Peneaux" on Justia Law

The Supreme Court reversed Defendant's misdemeanor conviction for intentional damage to property following a court trial, holding that the circuit court erred by accepting the argument of the prosecutor that intentional damage to property is a strict liability offense for which a defendant who caused damage is necessarily guilty.Defendant was charged with intentional damage to property as a Class 1 misdemeanor for striking the windshield of a vehicle with her hand held in a fist, cracking it. During trial, Defendant argued that she could not be guilty because she did not intend to crack the windshield. The circuit court found Defendant guilty, aligning its rationale with the State's strict liability theory. The Supreme Court reversed, holding that intentional damage to property, as described S.D. Codified Laws 22-34-1, requires the State to prove that the Defendant acted with the specific intent to cause damage to the subject property. View "State v. Vandyke" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of first-degree rape and two counts of sexual contact with a child under the age of sixteen, holding that Defendant was not entitled to relief on his claims of error.After a jury trial, Defendant was found guilty of rape and sexual contact with a minor and sentenced to two consecutive sixty-year terms of imprisonment on the rape convictions. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Defendant's motion for judgment of acquittal on the two rape charges; (2) the submission of the sexual contact charges to the jury did not violate the prohibition against double jeopardy; (3) there was no improper bolstering of witnesses at trial by either the circuit court or the prosecution; (4) the circuit court did not abuse its discretion by denying Defendant's motion for a new trial; (5) Defendant's sentence neither violated the constitutional prohibition against cruel and unusual punishment, nor did it constitute an abuse of discretion; and (6) no other prejudicial error occurred. View "State v. Manning" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of nine counts of third-degree rape involving J.C., holding that Defendant was not entitled to relief on any of his allegations of error.During the trial, the circuit court rejected the legal basis of Defendant's defense theory that J.C. gave "advance consent" to to sexual penetration before she passed out and became incapable of of giving contemporaneous consent. The circuit court rejected the legal basis of the defense and consequently excluded evidence that J.C. gave advance consent. The Supreme Court affirmed on appeal, holding (1) there was no error in the circuit court's decision regarding the advance consent theory and the court's exclusion of the relevant evidence; (2) the circuit court did not err by failing to instruct the jury on a definition of intoxication; and (3) this Court declines to address Defendant's claim of ineffective assistance of counsel on direct review. View "State v. Malcolm" on Justia Law

The Supreme Court affirmed Defendant's conviction for attempted first-degree murder, four counts of aggravated assault, and commission of a felony while armed with a firearm, holding that there was no error in the proceedings below.After a jury trial, Defendant was convicted. After a habitual offender trial, the jury found that Defendant had five prior felony convictions and ordered him to serve twenty-five years for attempted first-degree murder. The Supreme Court affirmed, holding that applying the correct standard leads to the conclusion that sufficient evidence supported the circuit court's decision to deny Defendant's motions for judgment of acquittal. View "State v. At The Straight" on Justia Law

The Supreme Court affirmed Defendant's conviction of open container and driving under the influence (DUI) and imposing a suspended imposition of sentence, holding that the circuit court did not err in denying Defendant's motion to suppress.Based on information obtained during a 911 call made by Defendant's daughter reporting that Defendant may be drinking and driving and providing Defendant's location officers conducted a traffic stop of Defendant's van and then arrested her for DUI. Defendant filed a motion to suppress, arguing that the traffic stop was an unconstitutional search and seizure. The circuit court denied the motion and found Defendant guilty. The Supreme Court affirmed, holding that, under the totality of the circumstances, the circuit court properly concluded that law enforcement had reasonable suspicion to believe that Defendant was driving under the influence of alcohol at the time of the stop. View "State v. Rosa" on Justia Law

The Supreme Court affirmed Defendant's conviction of third-degree rape, entered following a jury trial, holding that there was sufficient evidence in the record to sustain the conviction, and therefore, the circuit court did not err in denying Defendant's motion for a judgment of acquittal.After a jury trial, Defendant was found guilty of third-degree rape and sentenced to ten years in prison with eight years suspended. On appeal, Defendant argued that the evidence did not prove beyond da reasonable doubt that actual penetration occurred, as required by S.D. Codified Laws 22-22-1(3). The Supreme Court affirmed, holding that there was sufficient evidence in the record to support the jury's verdict finding Defendant guilty of third-degree rape. View "State v. McDermott" on Justia Law