Justia Civil Rights Opinion Summaries

Articles Posted in South Dakota Supreme Court
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The Supreme Court affirmed Defendant's conviction of second-degree rape and simple assault, holding that the circuit court did not err when it denied Defendant's motion for a judgment of acquittal on the second-degree rape charge.Specifically, the Supreme Court held (1) there was sufficient evidence to sustain Defendant's conviction for second-degree rape because there was sufficient evidence of "force" as required under S.D. Codified Laws 22-22-1(2); (2) the circuit court did not commit plain error by allowing certain testimony; and (3) the representation provided by Defendant's trial counsel was not constitutionally deficient. View "State v. Townsend" on Justia Law

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The Supreme Court affirmed Defendant's convictions for vehicular homicide and driving under the influence, holding that the evidence was sufficient to support the convictions and that the circuit court's error in denying Defendant's motion to suppress was harmless.On appeal, Defendant argued that the circuit court erred when it denied her motion to suppress a statement that she made to law enforcement officers at the hospital and when it denied her motion for a judgment of acquittal. The Supreme Court affirmed, holding (1) the circuit court erred by denying Defendant's suppression motion, but the error was harmless given the overwhelming evidence against her; and (2) the evidence was sufficient to sustain Defendant's convictions. View "State v. Angle" on Justia Law

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The Supreme Court affirmed Defendant's sentence entered after he pled nolo contendere to three counts of possession of child pornography pursuant to a plea agreement, holding that the sentence did not violate the Eighth Amendment or constitute an abuse of discretion.The circuit court sentenced Defendant to ten years' incarceration, with six years suspended on each count and credit for time served. The court ordered counts one and two to be served consecutively with count three to run concurrently. The Supreme Court affirmed, holding (1) Defendant's sentence did not violate the Eighth Amendment's prohibition against cruel and unusual punishment; and (2) the circuit court did not abuse its discretion in sentencing Defendant. View "State v. Miles" on Justia Law

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The Supreme Court affirmed Defendant's convictions and sentences for kidnapping, rape, aggravated assault, and commission of a felony with a firearm, holding that there was no error or abuse of discretion.Specifically, the Supreme Court held (1) the circuit court did not abuse its discretion when it granted the State's motion in limine regarding erotic asphyxiation; (2) Defendant's prosecutorial misconduct claims were unfounded; (3) the circuit court did not err in denying Defendant's motion for judgment of acquittal on all counts on which Defendant was convicted; and (4) Defendant's seventy-five-year sentence was not grossly disproportionate in violation of the Eighth Amendment. View "State v. Seidel" on Justia Law

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The Supreme Court affirmed Defendant's conviction of two counts of aggravated assault and two counts of simple assault for attacking his former significant other, Rosa Sosa, holding that the circuit court did not err in excluding evidence of Sosa's drug use and that Defendant was not entitled to relief on his double jeopardy claims.Specifically, the Supreme Court held (1) the circuit court did not err in granting the State's motion in limine to exclude evidence of the victim's methamphetamine use; and (2) Defendant's convictions for multiple counts of assault did not subject him to double jeopardy. View "State v. Babcock" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder and other offenses, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Court held (1) if the circuit court erred in denying Defendant's motion to suppress his statements to law enforcement, the error was harmless because the statements were cumulative to other evidence received; (2) the circuit court did not abuse its discretion or commit prejudicial error by refusing to declare certain witnesses adverse; (3) Defendant's Sixth Amendment rights were not violated; and (4) the evidence presented at trial was sufficient to support Defendant's guilty verdict on all counts. View "State v. Quinones Rodriguez" on Justia Law

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The Supreme Court affirmed Defendant's conviction of two counts of vehicular homicide, one count of vehicular battery, and driving while under the influence of alcohol, holding that the circuit court did not commit error in the proceedings below.On appeal, Defendant argued that the circuit court erred in denying his motion to suppress a warrantless blood draw and asked the Supreme Court to review his ineffective assistance of counsel claims on direct appeal. The Supreme Court affirmed, holding (1) the circuit court did not err when it denied Defendant's motion to suppress his warrantless blood draw; and (2) Defendant's ineffective assistance of counsel claim is not cognizable on direct appeal. View "State v. Vortherms" on Justia Law

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The Supreme Court affirmed Defendant's conviction of simple assault on a law enforcement officer, holding that Defendant was not entitled to relief on any of her assignments of error.Specifically, the Supreme Court held (1) the circuit court did not err when it denied Defendant's motion for a judgment of acquittal; (2) the circuit court did not err by instructing the jury on facts not entered into the record; and (3) the circuit court did not violate Defendant's constitutional right of confrontation under the Sixth Amendment by admitting a certified conviction from Codington County in the habitual offender trial. View "State v. McReynolds" on Justia Law

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The Supreme Court affirmed Defendant's conviction of eight counts of first-degree child rape and four counts of sexual contact with a child, holding that no prejudicial error occurred in the proceedings below.Specifically, the Supreme Court held (1) the circuit court did not err in denying Defendant's motion for a bill of particulars and his motion to quash the indictment; (2) the circuit court did not abuse its discretion in admitting internet searches and images on Defendant's cell phones and tablet; (3) the circuit court did not abuse its discretion in admitting a witness's hearsay statements; (4) the circuit court did not err in failing to enter a judgment of acquittal on any of the charges; and (5) Defendant's sentences were not cruel and unusual in violation of the Eighth Amendment. View "State v. Snodgrass" on Justia Law

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The Supreme Court reversed the orders of the circuit court sustaining Defendants' motions to suppress evidence seized by law enforcement, pursuant to a search warrant, at the apartment where Defendants resided, holding that probable cause existed for the issuance of the search warrant.Defendants - Carrie Lynn Ostby and Dana Olmsted - were indicted on drug-related charges. The circuit court granted Defendants' motions to suppress, determining that probable cause did not exist for the warrant to search Defendants' apartment and that the exigent circumstances exception to the warrant requirement was inapplicable. The Supreme Court reversed, holding (1) the affidavit in support of the search warrant established probable cause to search the apartment where Defendants resided; and (2) therefore, it was unnecessary to consider whether the good-faith exception applied to the exclusionary rule. View "State v. Ostby" on Justia Law