Justia Criminal Law Opinion Summaries

In this case from the Supreme Court of South Dakota, the defendant, Matthew Allan Carter, was convicted of first-degree rape of a minor. The victim, referred to as E.W., was the five-year-old daughter of Carter's then-girlfriend, Nycole Morkve. E.W. disclosed to her mother and grandmother that Carter, known as “Daddy Matt," had “licked” her “lady parts.” Medical examination revealed that E.W. had gonorrhea, a sexually transmitted infection, and a subsequent test showed that Carter also had gonorrhea. Additionally, a search of Carter's residence uncovered a hard drive containing videos of child pornography.On appeal, Carter argued that the trial court erred in its rulings related to evidence, his motion for acquittal, and his claim of ineffective assistance of counsel. The Supreme Court of South Dakota reviewed these issues and affirmed the trial court's decisions. The court found that the trial court did not abuse its discretion in allowing the jury to view brief clips of the child pornography videos found on Carter's hard drive, as they were relevant to proving Carter's intent and motive. The court also found that the trial court did not err in admitting E.W.'s statements about the abuse, as they were reliable and corroborated by other evidence. Additionally, the court held that there was sufficient evidence for a rational trier of fact to have found beyond a reasonable doubt that Carter orally penetrated E.W. Finally, the court declined to address Carter's ineffective assistance of counsel claims, as the record on that issue was not sufficiently developed.The court, therefore, affirmed Carter's conviction for first-degree rape. View "State V. Carter" on Justia Law

In the case brought before the Supreme Court of the State of South Dakota, Elias Richard was convicted of second-degree murder for the shooting death of Vernall Marshall. Richard appealed the decision, arguing that the circuit court erred in allowing evidence of his gang affiliation and in denying his motion for mistrial due to the State’s failure to disclose a forensic report.On Christmas Eve 2020, Richard, along with several others, confronted Marshall regarding inappropriate text messages Marshall had sent to a minor. Richard was part of a gang known as the Dark Side Family, and the confrontation ended with Marshall being shot twice in the back and left for dead. The court allowed reference to Richard’s gang affiliation to explain his involvement in the incident, which was otherwise unconnected to him.Richard also sought a mistrial after it was revealed during trial that the State had not disclosed a forensic report. This report contradicted the defense's opening statement claim that shell casings found at the crime scene matched those found at a co-defendant’s apartment. The court, however, denied the motion, deeming the failure to disclose inadvertent and not prejudicial.On appeal, the Supreme Court affirmed the circuit court's decisions. It concluded that the evidence of Richard’s gang affiliation was relevant to explain his motive for confronting Marshall and did not unfairly prejudice the jury. The court also found that the failure to disclose the forensic report did not materially prejudice Richard's defense, as his primary strategy was to argue that another defendant was the shooter, a theory that was not undermined by the undisclosed report. Therefore, the court held that the circuit court did not err in denying Richard's motion for mistrial. View "State V. Richard" on Justia Law

In this case, the defendant, Manegabe Chebea Ally, was convicted of first-degree manslaughter for the death of a 16-month-old child. He was sentenced to a 45-year prison term with 20 years suspended. Following his conviction, Ally appealed, alleging that his trial counsel was ineffective in several respects. After a series of evidentiary hearings, the habeas court granted him relief, determining that his counsel was indeed ineffective and that the cumulative effect of these deficiencies prejudiced his defense. The habeas court determined that Ally's right to a fair trial was violated.The Supreme Court of the State of South Dakota, however, reversed the decision of the habeas court. The Supreme Court found that while Ally's counsel's opening statement included an imprecise remark, this mistake did not undermine the adversarial process or deprive Ally of a fair trial. The Court also found that Ally's defense counsel made a reasonably strategic decision to exclude parts of Ally's three interviews with a detective and to not elicit additional testimony from a medical expert. Although the Court acknowledged that the defense counsel's failure to disclose a certain video to the prosecutor deviated from prevailing professional norms, it did not result in significant prejudice to Ally. The Court therefore concluded that Ally did not receive ineffective assistance of counsel at his 2012 trial, and the decision of the habeas court was reversed. View "Ally V. Young" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree manslaughter and sentencing her to forty years in prison with twenty years suspended, holding that Defendant was not entitled to relief on her allegations of error.Specifically, the Supreme Court held (1) the circuit court did not abuse its discretion when it denied Defendant's motion for a new trial based on an alleged violation of Brady v. Maryland, 373 U.S. 83 (1963); (2) there was sufficient evidence from which a jury could find Defendant guilty of first-degree manslaughter, as defined in S.D. Codified Laws 22-16-15(4); and (3) the circuit court did not abuse its discretion in sentencing Defendant. View "State v. Peltier" on Justia Law

The Supreme Court affirmed the judgment of the habeas court dismissing Appellant's petition for a writ of habeas corpus, holding that the court correctly applied res judicata to determine that Appellant could not demonstrate prejudice as to his ineffective assistance of counsel claim.Appellant pled guilty to first-degree manslaughter and was sentenced to life imprisonment. In his petition for a writ of habeas corpus, Appellant argued that he was actually innocent and that his trial counsel rendered ineffective assistance by not assuring that he understood his right to assert a claim of self-defense. In granting the State's motion to dismiss, the habeas court concluded that Appellant's claims were precluded from relitigation under the doctrine of res judicata because the Court had previously considered them on direct appeal. The Supreme Court affirmed, holding that the habeas court did not err in applying res judicata to determine that Appellant could not demonstrate prejudice under Strickland v. Washington, 466 U.S. 668 (1984). View "Ceplecha v. Sullivan" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying the State's motion to dismiss the second petition for a writ of habeas corpus filed by David Lee in 2004, holding that Lee's claim for habeas relief must be denied.Lee brought his second habeas corpus petition in 2004, alleging that his habeas counsel was ineffective for failing to seek a certificate of probable cause in his first habeas corpus proceeding. It wasn't until 2019, however, that Lee served the State with the provisional writ. The State moved to dismiss the writ, arguing that after the expiration of the statutory 30-day period for filing a motion for a certificate of probable cause under S.D. Codified Laws 21-27-18.1, the court did not have the authority to issue a certificate of probable cause. The circuit court denied the motions to dismiss. The Supreme Court reversed, holding (1) Lee had no right to appeal absent a certificate of probable cause issued by the habeas court or a member of the Supreme Court, and Lee had no right to a certificate of probable cause; and (2) even if Lee's habeas counsel was ineffective, it did not deprive Lee of any constitutional or statutory right that may be vindicated in a habeas corpus proceeding. View "Lee v. Weber" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of second-degree murder and sentencing him to forty years in prison, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) as concerning the prosecutor's effort to conceal the State's involvement in Defendant's transfer proceedings, the circuit court properly exercised its discretion to neutralize any error; (2) the circuit court acted within its discretion to denying Defendant's motion for mistrial; (3) viewed in their entirety, the instructions given to the jury correctly stated the applicable law; (4) the exercise of the circuit court's discretion did not contravene Defendant's right to present a complete defense; and (5) Defendant's sentence could not be described as grossly disproportionate to his crime. View "State v. Black Cloud" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree manslaughter and aggravated assault and sentencing him to life imprisonment, holding that Defendant's sentence did not violate the Eighth Amendment.Defendant pled guilty to first-degree manslaughter and aggravated assault. The circuit court sentenced Defendant to life without the possibility of parole for first-degree manslaughter and to a term of fifteen years for aggravated assault to run concurrently with his life sentence. Defendant appealed, arguing that his life sentence constituted cruel and unusual punishment and that the circuit court abused its discretion by imposing a life sentence without the possibility of parole. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion. View "State v. Caffee" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of rape in the first degree and his sentence of two consecutive twenty-five-year prison terms, holding that the circuit court did not err in denying Defendant's motion for a mistrial or in instructing the jury.During trial, defense counsel cross-examined the victim at issue in order to demonstrate what counsel believed were inconsistencies between the victim's testimony and a prior incident. Based on the belief that counsel's questions had prompted the victim about uncharged events involving Defendant, the prosecutor asked the victim about this other conduct. Defendant later moved for a mistrial on the grounds that he had not received notice of the State's intent to introduce other acts evidence,The circuit court denied the motion and convicted Defendant. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it denied Defendant's motion for mistrial or in failing to include Defendant's proposed instruction regarding other acts of rape. View "State v. Ortiz-Martinez" on Justia Law

The Supreme Court held that S.D. Codified Laws 32-34-5, which punishes defendants for their failure to stop and comply with the requirements of S.D. Codified Laws 32-34-3, applies regardless of whether the defendant's acts were intentional and that the evidence was sufficient to support Defendant's conviction under section 32-34-5.After a jury trial, Defendant was found guilty of aggravated assault and felony hit and run. Defendant appealed. Appellate counsel then submitted a Korth briefing setting forth the issues Defendant wished to raise on appeal. The Supreme Court addressed only the brief's arguably meritorious issue, namely, whether the felony hit and run statute applies to intentional conduct. The Court then affirmed, holding that the felony hit and run statute applies regardless of whether the defendant's acts were intentional. View "State v. Kwai" on Justia Law