Justia Civil Rights Opinion Summaries

Articles Posted in South Dakota Supreme Court
by
The Supreme Court affirmed Defendant's conviction for first-degree burglary and grand theft, holding that the circuit court did not err when it denied Defendant's motion to suppress and when in denied Defendant's motion for expert fingerprint testing.Defendant filed a motion to suppress gun evidence that was returned to the owner before trial, arguing that the State would be unable to establish a proper chain of custody. The circuit court denied the motion to suppress. The Supreme Court affirmed, holding (1) although the law enforcement officers and the prosecutor did not comply with statutory standards before releasing the evidence to its owner, the circuit court did not err in denying the motion to suppress because the guns did not possess apparent exculpatory value; and (2) even if the circuit court abused its discretion by denying Defendant's request for fingerprint testing, there was no prejudice. View "State v. Zephier" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of second-degree rape and sexual contact involving a second victim, holding that Defendant's allegations of error were unavailing.Specifically, the Supreme Court held (1) the circuit court did not abuse its discretion by allowing evidence of Defendant's two prior alleged sexual assaults; (2) the admission of other act evidence did not violate Defendant's constitutional rights under the Double Jeopardy and Due Process Clauses; (3) the circuit court did not abuse its discretion when it denied Defendant's motion for a mistrial; (4) there was sufficient evidence to support the conviction; (5) the circuit court erred in admitting forensic laboratory reports by affidavit without affording Defendant the opportunity to cross-examine the analysts who conducted the testing and authored the reports, but the error was not prejudicial; and (6) Defendant's sentence did not violate the Eighth Amendment. View "State v. Taylor" on Justia Law

by
The Supreme Court affirmed the judgment of the circuit court denying Defendant's motion to suppress evidence obtained as a result of his encounter with police, holding that the circuit court properly denied the motion to suppress.Defendant was charged with possession of controlled substances, a loaded firearm while intoxicated, marijuana, and drug paraphernalia. Defendant filed a motion to suppress evidence obtained from a stop of his person on the basis that it violated the Fourth Amendment. The circuit court denied the motion, concluding that the search was done in accordance with Terry v. Ohio, 392 U.S. 1 (1968) and its progeny. The Supreme Court affirmed, holding (1) under the totality of the circumstances, the officers had reasonable suspicion to stop Defendant; and (2) therefore, the circuit court did not err by denying Defendant's motion to suppress. View "State v. Williams" on Justia Law

by
The Supreme Court affirmed the judgment of the circuit court convicting Defendant of second-degree murder and sentencing him to ninety years in prison, holding that Defendant's discretionary sentence did not offend the Eighth Amendment's prohibition against cruel and unusual punishment.Defendant pled guilty to second-degree murder. He was seventeen years old when he committed the crime. The circuit court sentenced Defendant to ninety years in prison, making him eligible for parole at age sixty-two. On appeal, Defendant argued that his sentence was unconstitutional because it violated categorical Eighth Amendment sentencing restrictions for juveniles and because it was disproportionately harsh. The Supreme Court disagreed, holding (1) because the court did not sentence Defendant to a mandatory life sentence and sufficiently considered his youth when fashioning his sentence, there was no Eighth Amendment violation; and (2) Defendant did not meet the initial requirement to show that his sentence was grossly disproportionate to his crime. View "State v. Quevedo" on Justia Law

by
The Supreme Court reversed Defendant's the order of the circuit court granting Defendant's motion to suppress evidence obtained as a result of Defendant's arrest, holding that the circuit court erred when it refused to consider the application of the attenuation doctrine and suppressed the evidence.Defendant was charged with possession of methamphetamine and false impersonation. Before trial, Defendant moved to suppress the evidence obtained as a result of her interaction with police officers on the grounds that the officers lacked reasonable suspicion to detain her. The circuit court granted the motion to suppress. Despite the State's argument that the attenuation doctrine applied, the circuit court did not analyze the applicability of the attenuation doctrine. The Supreme Court reversed, holding that because the connection between Defendant's detention and the subsequent search was interrupted by the discovery of the existence of a valid, preexisting and unrelated warrant, the attenuation factors weighed in favor of the State. View "State v. Mousseaux" on Justia Law

by
The Supreme Court affirmed Defendant's sentence of eighty years imprisonment with forty years suspended for first-degree manslaughter, holding that the sentence was not grossly disproportionate to the offense and did not violate the Eighth Amendment.Specifically, the Supreme Court held (1) Defendant's sentence was not grossly disproportionate to the offense of first-degree manslaughter under the Eighth Amendment; (2) at sentencing, the circuit court properly examined the events surrounding the offense, Defendant's character and history, and Defendant's rehabilitation prospects; and (3) the circuit court did not abuse its discretion in crafting the sentence. View "State v. Holler" on Justia Law

by
The Supreme Court affirmed Defendants' convictions of first-degree manslaughter and sentences of life imprisonment, holding that the circuit court did not err or abuse its discretion in either case.Daniel Ceplecha and his son, Rangler Ceplecha, each pled guilty to first-degree manslaughter pursuant to a plea agreement. Prior to sentencing, Defendants filed motions to withdraw their pleas, asserting that they acted in self-defense. The circuit court denied the motions. Thereafter, the circuit court sentenced each defendant to life in prison. The Supreme Court affirmed, that the circuit court (1) did not abuse its discretion in denying Rangler's motion for new counsel because he failed to establish a fair and just reason in support of his request; (2) did not abuse its discretion by denying Defendants' motions to withdraw their guilty pleas; and (3) did not abuse its discretion or violate the Eighth Amendment by imposing life sentences. View "State v. Ceplecha" on Justia Law

by
The Supreme Court reversed the denial of Defendant's motion to suppress evidence seized from his hotel room pursuant to a search warrant, holding that the officer who previously detained Defendant's vehicle and gathered information eventually contained in the search warrant affidavit did not have reasonable suspicion or probable cause to stop Defendant's vehicle and that all evidence obtained after the stop must be suppressed under the exclusionary rule.Defendant was stopped because the officer observed a brake light emit a white light. A consent search of the vehicle did not produce evidence of unlawful drugs, but the officer later found a foil ball in the vehicle, which tested positive for methamphetamine. Thereafter, police officers seized evidence from Defendant's hotel room pursuant to a search warrant. Defendant filed a motion to suppress, arguing that the officer did not have reasonable suspicion to stop his vehicle because it had two properly working brake lights. The circuit court denied the motion. The Supreme Court reversed, holding (1) the officer did not have reasonable suspicion or probable cause to stop Defendant's vehicle; and (2) once the information derived from the unlawful traffic stop was excluded from the search warrant affidavit, it lacked a substantial basis upon which probable cause could be found. View "State v. Tenold" on Justia Law

by
The Supreme Court affirmed the determination of the habeas court denying Appellant's petition for a writ of habeas corpus alleging ineffective assistance of counsel, holding that Appellant did not meet his burden to prove his trial counsel was ineffective when it made the strategic decision not to employ or consult experts.Appellant was convicted of the first-degree murder of his wife and received a mandatory sentence of life imprisonment without the possibility of parole. Appellant later sought a writ of habeas corpus, arguing that his trial counsel rendered ineffective assistance because he did not engage any expert witnesses to evaluate certain evidence. The circuit court denied the habeas petition. The Supreme Court affirmed, holding that where defense counsel's decisions were reasonable to advance Defendant's defense theory and where Defendant could not satisfy Strickland's prejudice requirement, the habeas court did not err when it denied Appellant's habeas petition. View "Reay v. Young" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of first-degree rape of a child under age thirteen, holding that the circuit court erred in admitting statements from an unavailable witness, but the error was harmless.On appeal, Defendant argued that the trial judge's order admitting, as other acts evidence, statements from an unavailable witness violated his Sixth Amendment right to confront and cross-examine the witnesses against him. The Supreme Court affirmed, holding (1) the statements at issue were testimonial and of a constitutional magnitude; (2) the circuit court's decision to admit the statements violated Defendant's Sixth Amendment right of confrontation; but (3) the affect of the circuit court's error in admitting the statements at trial was harmless beyond a reasonable doubt. View "State v. Richmond" on Justia Law