Justia Civil Rights Opinion Summaries

Articles Posted in South Dakota Supreme Court
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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

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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

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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

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The Supreme Court reversed the decision of the circuit court finding co-defendants Adrianna Reecy and Kevin Dickerson guilty of robbery and burglary and also finding Dickerson guilty of aggravated assault against Julio Rojas, holding that exclusion of certain evidence resulted in violation of both defendants' Sixth Amendment right of confrontation.On appeal, both defendants argued that the circuit court erred in precluding any reference to Rojas's immigration status and in admitting into evidence an exhibit listing transactions from Rojas's debit card. The Supreme Court agreed and reversed, holding (1) the circuit court's exclusion of the immigration evidence was error, and the error was not harmless; and (2) the circuit court erred in admitting the bank records at issue because the State did not lay an adequate foundation for the admission of the documents and the court erroneously determined that Rojas was a qualified witness, as contemplated by the exception to the hearsay rule. View "State v. Dickerson" on Justia Law

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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

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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

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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

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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

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The Supreme Court affirmed in part and reversed in part the judgment of the circuit court denying both parties' summary judgment motions as to Plaintiff's 42 U.S.C. 1983 claims, holding that the circuit court erred in denying summary judgment in favor of the City of Sioux Falls.Plaintiff brought this action against certain officers of the Sioux Falls Police Department and the City of Sioux Falls. The police officers and the City filed a motion for summary judgment. The circuit court (1) concluded that the officers were not entitled to qualified immunity; (2) denied summary judgment on Plaintiff's claim against the City due to material issues of fact. The Supreme Court held that the circuit court (1) erred in denying summary judgment on Plaintiff's claim that the officers' warrantless entry into her apartment violated her constitutional right to be free from unreasonable searches and seizures; (2) erred in denying the City's motion for summary judgment; and (3) properly concluded that material issues of fact were in dispute on the question of whether the officers used excessive force such that Defendants were not entitled to qualified immunity as a matter of law on this section 1983 claim. View "Boggs v. Pearson" on Justia Law

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The Supreme Court affirmed Defendant's conviction of driving a vehicle with alcohol in the blood in violation of S.D. Codified Laws 32-23-1(1), holding that the magistrate court's finding that Defendant provided valid, voluntary consent to the blood draw was not clearly erroneous.After law enforcement officers arrested Defendant for driving under the influence one of the officers asked Defendant if he would consent to a blood draw. Defendant twice answered, "okay," and his blood was drawn without a warrant. Defendant filed a motion to suppress, arguing that the blood draw was taken without a warrant or his valid consent. The magistrate court denied the motion. The circuit court affirmed. The Supreme Court affirmed, holding that the circuit court (1) applied the correct standard of review to the magistrate court's decision; and (2) did not err in affirming the magistrate court's decision that Defendant provided valid, voluntary consent to the blood draw. View "State v. Slepikas" on Justia Law