Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of driving under the influence (DUI), abuse of or cruelty to a minor, reckless driving, and other offenses, holding that there was no error in the proceedings below.On appeal, Defendant argued that the circuit court erred by denying his motion for judgment of acquittal, by denying his motion for mistrial, and by erroneously instructing the jury regarding blood test refusal evidence. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Defendant's motion for judgment of acquittal on his DUI, reckless driving, and abuse of or cruelty to a minor convictions; (2) did not err by denying Defendant's motion for mistrial; and (3) properly instructed the jury regarding the blood test refusal evidence. View "State v. Nelson" on Justia Law

The Supreme Court affirmed the magistrate court's decision granting Defendant's motion to suppress, holding that the magistrate court did not err in determining that the community caretaker exception to the Fourth Amendment did not apply.After Sioux Falls dispatch received a call from a six-year-old boy saying that "daddy was being mean to mom" and that his dad was leaving to go to his car an officer followed the dad (Defendant) in his automobile. The officer initiated a traffic stop and, after further investigation, placed Defendant under arrest for driving under the influence and driving with a suspended license. Defendant filed a motion to suppress, arguing that the officer stopped his car without probable cause or a reasonable and articulable suspicion. The magistrate court granted the motion to suppress. The Supreme Court affirmed, holding that the officer's actions were beyond the scope of a community caretaker, and therefore, Defendant's motion to suppress was properly granted. View "State v. Grassrope" on Justia Law

The Supreme Court dismissed for lack of jurisdiction the judgment of the circuit court denying Appellant's motion to modify his sentence, holding that this Court did not have appellate jurisdiction over Appellant's appeal.Pursuant to a plea agreement, Appellant pled guilty to a felony charge of intentional damage to property in exchange for the State's recommendation for a one-year suspended sentence to run concurrent with the sentence Appellant was already serving. The circuit court sentenced Appellant to six years in prison with one year suspended to run consecutive to the prior sentence. Appellant later filed a motion to modify his sentence based on his deteriorating health. The circuit court denied the request. The Supreme Court dismissed Appellant's appeal, holding that it lacked jurisdiction to hear the appeal. View "State v. Edelman" on Justia Law

The Supreme Court affirmed the judgment of the habeas court dismissing Defendant's application for habeas corpus, holding that the court did not err.A jury convicted Defendant of fourteen sex offenses. On appeal, Defendant argued that his due process right to jury unanimity was denied and that the prosecutor's remarks during opening statement denied him a fair trial. The Supreme Court affirmed. Defendant later filed an application for writ of habeas corpus alleging ineffective assistance of counsel based on the errors he alleged on appeal. The habeas court dismissed the application. The Supreme Court affirmed, holding (1) Defendant was precluded from demonstrating prejudice for Strickland purposes in a subsequent habeas corpus proceeding; and (2) the habeas court properly dismissed Defendant's amended application for a writ of habeas corpus on summary judgment. View "Neels v. Dooley" on Justia Law

The Supreme Court affirmed the judgment of the habeas court dismissing Appellant's application for habeas corpus relief alleging ineffective assistance of counsel, holding that there was no error.Defendant was convicted of one count of third-degree rape. On appeal, Defendant asserted that plain error occurred in the prosecutor's alleged vouching of the victim during closing argument. The Supreme Court affirmed. Defendant later filed an application for habeas corpus relief, alleging ineffective assistance of counsel (IAC) based, in part, on trial counsel's failure to object to the prosecutor's alleged misconduct. The habeas court denied relief. The Supreme Court affirmed, holding (1) the habeas court properly dismissed Defendant's IAC claim related to the prosecutor's improper vouching was res judicata; and (2) this Court lacked jurisdiction to consider Defendant's remaining IAC claim. View "Harris v. Fluke" on Justia Law

The Supreme Court affirmed the judgment of the circuit court imposing a penitentiary sentence after Defendant pleaded guilty to two felonies, holding that the State's comments at sentencing did not breach its implied obligation of good faith under the terms of the plea agreement.Pursuant to a plea agreement, Defendant pleaded guilty to one count of abuse or cruelty to a minor, in exchange for the State's recommendation for a suspended execution of sentence, and also pleaded guilty to one count of a controlled substance, in exchange for the State's recommendation of a fully suspended sentence. The circuit court accepted Defendant's guilty pleas and then sentenced her to twelve years' imprisonment with eight years suspended on the child abuse conviction. On appeal, Defendant argued that the State's sentencing argument violated the plea agreement. The Supreme Court affirmed, holding that Defendant's argument was insufficient to meet her burden under plain error review. View "State v. Guziak" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for assault by a jail inmate - contract with bodily fluids, simple assault against an inmate, and threatening a law enforcement officer, holding that there was no error or abuse of discretion.On appeal, Defendant argued that the circuit court abused its discretion by admitting a surveillance video into evidence and that the error prejudiced the outcome of his trial. Specifically, Defendant argued that a lay foundation was required under S.D. Codified Laws 19-19-901(b)(1) to authenticate the video and that that the necessary foundation was not laid in this case. The Supreme Court affirmed, holding that the evidence adequately supported the circuit court's finding that the video was an accurate recording of the incident leading to Defendant's convictions. View "State v. Reeves" on Justia Law

The Supreme Court reversed the judgment of the circuit court committing seventeen-year-old D.S. to the custody of the Department of Corrections (DOC) pursuant to S.D. Codified Laws 26-8C-7 after adjudicating him of first-degree rape, holding that the court committed reversible error because its findings and conclusions were insufficient to permit meaningful review.In announcing its disposition, the circuit court did not address whether the recommendations before it for community supervision and outpatient treatment were viable alternatives to DOC custody or whether commitment to the DOC was the least restrictive alternative in D.S.'s best interest. The day after the deposition hearing, the court entered written findings of fact and conclusions of law stating simply that there were no other viable alternatives and that commitment to the DOC was the least restrictive alternative. The Supreme Court reversed, holding that remand was required for the circuit court to make findings on the viability of a community-based supervision and treatment alternative and to reimpose a disposition consistent with the requirements of section 26-8C-7. View "In re D.S." on Justia Law

The Supreme Court affirmed the decision of the circuit court order several search warrants involving the Implicated Individual in this case and corresponding inventories to be unsealed, holding that there was no error.A special agent of the South Dakota Division of Criminal Investigation sought several search warrants involving the Implicated Individual, and the circuit court approved the warrants. The warrants, along with the supporting affidavits and inventories, were filed with the clerk of courts. At the agent's request, the circuit court sealed the search warrants but ultimately ordered that the search warrants and corresponding inventories be unsealed. The Supreme Court affirmed, holding that S.D. Codified Laws 23A-35-4.1 prohibits a court from sealing a search warrant or the verified inventory. View "In re Matter of Implicated Individual" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder but reversed the court's restitution order in part, holding that the restitution order did not comply with S.D. Codified Laws 23A-28-3.After finding Defendant guilty of second-degree murder, the circuit court imposed a mandatory sentence of life imprisonment, costs of prosecution and restitution. On appeal, Defendant argued, among other things, that the court erred in fashioning its order of restitution requiring him to pay future counseling costs and other expenses incurred by the victim's family members. The Supreme Court affirmed Defendant's conviction but reversed in part the restitution order, holding (1) the circuit court did not err in denying Defendant's motion for judgment of acquittal; (2) the circuit court did not abuse its discretion in its evidentiary rulings; and (3) the restitution order imposed arbitrary caps without specifying timeframes or mechanisms by which specific amounts to be reimbursed to the victim's family could be ascertained. View "State v. Falkenberg" on Justia Law