Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree rape, in violation of S.D. Codified Laws 22-22-1(1), holding that the court did not err in denying Defendant's request to withdraw his guilty plea.Defendant pled guilty to sexual penetration of a victim less than thirteen years of age. After a change of plea hearing but prior to sentencing, Defendant unsuccessfully filed a letter asking the circuit court to withdraw his guilty plea and requesting substitute counsel. After denying both requests the court sentenced Defendant to 100 years in prison with fifteen years suspended. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in denying Defendant's request to withdraw his guilty plea; and (2) this Court declines to address Defendant's ineffective assistance of counsel claim on direct review. View "State v. Alvarez" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant, after a jury trial, of two counts of first-degree rape, holding that the circuit court did not abuse its discretion in the way it handled Defendant's arraignment or in its evidentiary rulings and that misconduct that occurred during the State's closing rebuttal argument did not constitute prejudicial error.On appeal, Defendant claimed that his arraignment violated his due process rights and S.D. Codified Laws 23A-7-1 and that the circuit court abused its discretion in several of its evidentiary rulings. The Supreme Court disagreed and affirmed, holding (1) the challenged evidentiary rulings were without error and were not an abuse of discretion; and (2) while the prosecutor committed misconduct during closing argument, it was improbable that the prosecutor's misconduct altered the jury's verdict. View "State v. Hankins" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for habeas corpus, holding that the circuit court did not err in denying the petition after holding an evidentiary hearing.Appellant was convicted of three counts of first-degree rape and one count of sexual contact with a child under sixteen for raping and having sexual contact with his four-year-old autistic daughter. The conviction was affirmed on appeal. Appellant later filed a petition for habeas corpus alleging several instances of ineffective assistance of counsel. After a hearing, the circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to establish that his trial counsel provided ineffective assistance. View "Spaniol v. Young" on Justia Law

The Supreme Court affirmed Defendant's conviction for second-degree murder and aggravated battery of an infant, holding that the circuit court did not err during the proceedings below and that there was sufficient evidence to support the convictions.After a jury trial, Defendant was found guilty of second-degree murder and aggravated battery of an infant and sentenced to life imprisonment for the second-degree murder. Defendant appealed, arguing that the circuit court erred when it denied his motion to suppress statements made to law enforcement during a custodial interview and that there there was sufficient evidence to support his convictions. The Supreme Court disagreed, holding that Defendant's suppression motion was properly denied and that his convictions were supported by sufficient evidence. View "State v. Larson" on Justia Law

The Supreme Court affirmed Defendant's convictions of one count of aggravated assault and two counts of simple assault, holding that the circuit court did not err by denying Defendant's motion to sever or in admitted statements contained in recorded phone conversations while Defendant was in jail.Defendant was charged with one count of aggravated assault and two counts of simple assault arising from a stab wound inflicted on Melissa Greenwalt on February 20, 2019 and was also charged with the same offenses arising from an assault inflicted on Greenwalt with fists, leaving her with a broken jaw. After Defendant unsuccessfully moved to sever the charges based on the dates of the offenses a jury convicted him on the assault charges arising from the 2019 stabbing but acquitted him of the charges from the 2018 broken-jaw incident. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Defendant's motion to sever; and (2) did not err in admitting portions of the recorded phone calls made by Defendant to Greenwalt. View "State v. Loeschke" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree arson stemming from a fire that occurred in Defendant's home, for which she submitted a claim to her insurer seeking to recover for the damage to her home, holding that Defendant was not entitled to relief on her claims of error.On appeal, Defendant argued that the circuit court erred in denying her motion for judgment of acquittal and that she was denied her fundamental right to due process. The Supreme Court affirmed, holding (1) the circuit court's factual findings were legally sufficient to support a conviction of second-degree arson; (2) the circuit court did not err when it denied Defendant's motion for judgment of acquittal; and (3) Defendant was not denied her constitutional right to due process and a fair trial. View "State v. Krouse" on Justia Law

The Supreme Court affirmed the judgment of the circuit court determining that an offer from Dakota Legends Properties, LLP (DLP) was a bona fide offer that triggered Plaintiffs' right of first refusal to purchase the property, that Plaintiffs had been offered the right of first refusal, and that Plaintiffs did not exercise that right, holding that there was no error.Defendant entered into a lease agreement with Plaintiffs that gave Plaintiffs a right of first refusal to purchase the leased property at the same price and terms of any bona fide offer. After receiving an offer from DLP, Defendant notified Plaintiffs of the offer. Plaintiffs made two offers on the property, which Defendant rejected in favor of DLP's offer. Litigation followed, and the parties filed cross-motions for partial summary judgment about whether DLP's offer was "bona fide." The circuit court granted summary judgment in favor of Defendant, concluding that DLP's offer was a bona fide offer and that Plaintiff had not exercised her right of first refusal. The Supreme Court affirmed, holding that the circuit court's conclusions of law were without error. View "McCoy v. McCallum" on Justia Law

The Supreme Court reversed the order of the circuit court denying Meemic Insurance Company's motion to dismiss this action for lack of personal jurisdiction, holding that the minimum contacts necessary to support the exercise of personal jurisdiction in accordance with due process requirements were not satisfied.Catherine Davis was riding as a passenger on William Laeder's motorcycle when Richard Otten, who was also driving a motorcycle, collided with them. All three people sustained incapacitating injuries. Meemic had issued an insurance policy in Michigan to Davis, which was in effect at the time of the accident. Davis ultimately filed a complaint against Otten and Meemic alleging that Meemic breached its insurance contract with Davis by failing to compensate her under the underinsured motorist coverage and no-fault insurance terms of her policy. After the circuit court denied Meemic's motion to dismiss, Meemic filed a petition for intermediate appeal. The Supreme Court granted the petition and reversed, holding that the minimum contacts required to warrant a finding of jurisdiction were not met in this case. View "Davis v. Otten" on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Defendant of violating S.D. Codified Laws 40-1-23 for having a "potentially dangerous animal," holding that the circuit court erred in failing to make the required finding of whether the animal was dangerous.In City of Pierre v. Blackwell, 635 N.W.2d 581 (S.D. 2001), the Supreme Court held that Blackwell was not afforded due process when he was convicted based on the animal control officer's determination of dangerousness. The Supreme Court reversed Defendant's conviction in this case, holding (1) Blackwell mandates that due process requires a higher standard than that stated in section 40-1-1(5) to prove the dangerousness of an animal in a criminal proceeding; and (2) because the circuit court clarified that it would have acquitted Defendant but for the 40-1-1(5) language, Defendant's conviction must be reversed. View "State v. Alexander" on Justia Law

The Supreme Court affirmed the judgment of the habeas court denying Appellant's amended application for a writ of habeas corpus alleging that the indictment under which he was charged did not describe a public offense and that he was convicted and sentenced in violation of constitutional provisions prohibiting an ex post facto application of a criminal statute, holding that there was no error.Appellant pled nolo contendere to first-degree rape of a child under thirteen years of age and sexual contact without consent against his daughter. The habeas court denied the habeas application, concluding that Appellant's claim was non-jurisdictional and thus waived when he pled nolo contendere pursuant to a plea agreement with the State. The Supreme Court affirmed, holding that Appellant failed to assert a claim upon which his judgment could be void. View "Lacroix v. Fluke" on Justia Law