Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of aggravated assault, holding that the circuit court did not err in denying Defendant's motion for judgment of acquittal and his motion for a new trial.Defendant's conviction stemmed from a physical altercation with his girlfriend, K.C., an incident during which K.C. alleged that Defendant choked her. The jury found Defendant guilty of aggravated assault. Defendant subsequently filed a motion for a new trial based on a letter that K.C. sent to the court prior to sentencing stating that the prosecution manipulated and threatened her to testify. The circuit court denied the motion. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in denying Defendant's motions for judgment of acquittal and for a new trial. View "State v. Timmons" on Justia Law

The Supreme Court affirmed Defendant's convictions for seven counts, including aggravated assault by physical menace with a dangerous weapon and grand theft by receiving stolen property, holding that there was sufficient evidence to support the convictions.Defendant's convictions arose from two separate incidents involving an alleged shooting and an ensuing confrontation between Defendant and two other men. On appeal, Defendant challenged the circuit court's denial of his motion for acquittal, arguing that there was insufficient evidence to support the convictions. The Supreme Court affirmed, holding that there was sufficient evidence to support the jury's guilty verdict. View "State v. Ahmed" on Justia Law

The Supreme Court affirmed Defendant's sentence imposed in connection with his plea of guilty to attempted first-degree murder and commission of a felony with a firearm, holding that the sentence did not violate the Eighth Amendment, nor was it an abuse of the circuit court's sentencing discretion.Defendant and the State entered into a plea agreement under which Defendant agreed to plead guilty to attempted first-degree murder and commission of a felony with a firearm. After a sentencing hearing, the circuit court sentenced Defendant to a total of thirty years in prison. The Supreme Court affirmed, holding that the circuit court (1) did not abuse its discretion in imposing the sentence, and (2) Defendant failed to demonstrate that his sentence transgressed the Eighth Amendment's prohibition against cruel and unusual punishment. View "State v. Deleon" on Justia Law

The Supreme Court affirmed Defendant's conviction of burglary and two counts of simple assault arising from a home invasion, holding that Defendant was not entitled to relief on his allegations of error.After a jury trial, Defendant was convicted of burglary and simple assault. Defendant was tried on a part two habitual offender information alleging two prior felon convictions. The jury found Defendant to be a habitual offender. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Defendant's motion to suppress the show-up identification; (2) did not err in denying Defendant's motion for a mistrial; and (3) did not err in denying Defendant's motion for judgment of acquittal in the habitual offender trial. View "State v. Red Cloud" on Justia Law

In these three consolidated appeals the Supreme Court held that the State has discretion to charge juveniles under the provisions of either S.D. Codified laws 32-23-1 or S.D. Codified Laws 32.23-21.Defendants, all minors under the age of eighteen, were charged as adults in separate cases for driving a vehicle with a blood alcohol content (BAC) of more than .08, in violation of section 32-23-1(1). Each defendant filed a motion to dismiss, claiming that their status as juveniles stripped the magistrate courts presiding over their cases of jurisdiction. The magistrate courts dismissed the motions, and the circuit courts affirmed. The Supreme Court affirmed, holding that Defendants failed to support their argument that the language of the relevant statutes prevents the State from charging them in magistrate court with violations of section 32-23-1. View "State v. Bettelyoun" on Justia Law

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