Justia Civil Rights Opinion Summaries

Matthew Fuller was convicted of possessing more than two ounces but less than one-half pound of marijuana, a felony, and was placed on supervised probation. After two subsequent arrests, the State petitioned to revoke his probation. The court appointed two attorneys for Fuller, both of whom withdrew. The court did not appoint a third attorney and conducted the revocation hearing with Fuller representing himself. Fuller was found to have violated his probation and was sentenced to a previously suspended two-year prison term.The Circuit Court of the Third Judicial Circuit in Codington County, South Dakota, initially handled the case. Fuller was arrested following a traffic stop and charged with marijuana possession. He was released on bond and represented by multiple attorneys who withdrew. Fuller pled guilty to a lesser charge, and the court imposed a suspended sentence with probation. After his subsequent arrests, the court ordered him held without bond pending the revocation hearing. Fuller’s attorneys withdrew due to a breakdown in the attorney-client relationship, and the court did not appoint new counsel.The Supreme Court of the State of South Dakota reviewed the case. The court held that while Fuller was entitled to appointed counsel under state law, he did not demonstrate that the lack of counsel prejudiced the outcome of the revocation hearing. The court found sufficient evidence to support the probation violation, including Fuller’s use of methamphetamine. The court also rejected Fuller’s claims of judicial bias and due process violations, affirming the lower court’s decision to revoke his probation and execute the suspended sentence. View "State V. Fuller" 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 reversed the order of the circuit court suppressing statements made by Defendant during the execution of a search warrant, holding that the circuit court erred in concluding that Defendant's statements to a law enforcement officer during the execution of a search warrant were involuntarily made.Defendant was indicted for one count each of rape in the third degree and sexual contact with a person incapable of consenting. Defendant filed a motion to suppress the statements he made to law enforcement, arguing that his statements were obtained in violation of Miranda v. Arizona, 384 U.S. 436 (1996). The circuit court granted the motion, concluding that Defendant's statements were involuntarily made under the Due Process Clause. The Supreme Court reversed, holding that, based on a review of the totality of the circumstances, the circuit court erred in concluding that Defendant's statements to law enforcement were involuntarily made. View "State v. Ghebre" 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 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 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 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 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 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