Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of first-degree kidnapping, second-degree rape, and aggravated assault. The Supreme Court affirmed Defendant's convictions. Defendant subsequently filed an amended application for writ of habeas corpus, alleging that he was denied effective assistance of counsel, a fair trial, and due process of law. The habeas court denied the writ. The Supreme Court affirmed, holding (1) the habeas court correctly determined that Defendant failed to demonstrate ineffective assistance of counsel; (2) Defendant's due process claim regarding cross-examination of the victim concerning her sexual activity before the rape and her post-rape drug charge were res judicata; and (3) the habeas court correctly determined that Defendant's remaining due process argument lacked evidentiary support. View "Fast Horse v. Weber" on Justia Law

Defendant and his stepson were jointly charged with thirteen felonies. Prior to trial, Defendant unsuccessfully moved to sever charges and for relief from prejudicial joinder. At trial, Defendant filed a motion for judgment of acquittal on all charges stemming from two of the burglaries, which the trial court also denied. Defendant was subsequently convicted on nine of the thirteen felonies. The Supreme Court affirmed, holding that the trial court did not err in (1) denying Defendant's motion for judgment of acquittal because the evidence was sufficient to support Defendant's convictions; and (2) denying Defendant's motion to sever charges and for relief from prejudicial joinder because the charges were properly joined and Defendant failed to show the denial of his motion to sever charges resulted in clear prejudice to his substantial rights. View "State v. Dowty" on Justia Law

The South Dakota Department of Labor and Regulation, Unemployment Insurance Division disqualified Plaintiff from unemployment insurance benefits based on Plaintiff's alleged failure, without good cause, to accept work she was capable of performing. After Plaintiff missed a telephonic hearing on her appeal, an ALJ entered an order of dismissal and denied Plaintiff's request to reopen for failure to show good cause. The circuit court affirmed, concluding that the Department did not err in refusing to reopen Plaintiff's claim. The Supreme Court affirmed dismissal, holding that Plaintiff did not provide evidence of untimely receipt of her notice of the hearing to carry her burden to show good cause, and therefore, Plaintiff received sufficient due process. View "Eiler v. Dep't of Labor & Regulation" on Justia Law

Hutterville Colony, a nonprofit religious corporation, had two opposing factions. Both factions sought exclusive power over Hutterville. Their schism led to two lawsuits, including one faction's suit seeking judicial dissolution of Hutterville. Eventually, the Supreme Court ordered dismissal of the suit, concluding that the circuit court lacked subject matter jurisdiction to order judicial dissolution of Hutterville. This appeal concerned the circuit court's actions following the Court's decision. The Supreme Court affirmed, holding (1) the circuit court did not err when it continued to exercise jurisdiction over Hutterville and its property following remittitur; (2) the circuit court had the authority and duty to wind up the receivership and discharge the receiver; (3) the circuit court did not abuse its discretion in ordering payment of the receiver's fees and expenses from receivership funds and allowing the receiver to use receivership funds to pay the expenses of third parties; (4) the circuit court did err in releasing the receiver from liability, as the receiver's appointment and receivership were valid under state law; and (5) the circuit court did not err in ordering the receiver to return receivership funds to the corporation. View "Wipf v. Hutterville Hutterian Brethren" on Justia Law

After a jury trial, Defendant was convicted of manslaughter in the first degree. The Supreme Court affirmed, holding that the trial court (1) did not abuse its discretion in denying Defendant's motion to suppress and in admitting a video of Defendant's first interrogation, as Defendant made a knowing, voluntary, and intelligent waiver of her Miranda rights in the first interrogation; (2) did not err in refusing to instruct the jury on the lesser offense of manslaughter in the second degree; and (3) did not err in denying a jury instruction on burglary and allowing Defendant's counsel to appropriately argue the elements of justifiable homicide. View "State v. Waloke" on Justia Law

Defendant was indicted for murder in the second degree and aggravated assault after stabbing two men during an altercation. Defendant moved to suppress statements he made during a custodial interrogation, arguing that he had not validly waived his Miranda rights and that his statements were not voluntary. The circuit court denied the motion. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that Defendant's statements were obtained pursuant to a valid Miranda waiver and that the statements were voluntarily made; and (2) there was sufficient evidence to support the jury's rejection of Defendant's claim of self-defense. View "State v. Strozier" on Justia Law

After a jury trial, Defendant was convicted of driving under the influence of alcohol and for an open container violation. Defendant appealed, arguing that the trial court incorrectly denied his motion to suppress evidence obtained after the stop of his vehicle because the law enforcement officer had no reasonable suspicion of a violation of law to support the stop. The Supreme Court affirmed the conviction, holding that the circuit court did not err in denying Defendant's motion to suppress because the officer had a reasonable suspicion that Defendant's crossing of the fog line violated a statute requiring Defendant's vehicle to be "driven as nearly as practicable entirely within a single lane." View "State v. Hett" on Justia Law

Defendant, who was born in Mexico but moved to the United States before he was one year old, pleaded guilty to possession of marijuana. The United States later commenced removal proceedings against Defendant and Defendant was deported. Defendant later re-entered the United States. Defendant filed a motion to re-open and vacate his conviction for felony possession of marijuana, arguing that his counsel was deficient and that he would not have pleaded guilty if his counsel had advised him of the potential deportation consequences. The trial court denied the motion. The Supreme Court affirmed, holding that the U.S. Supreme Court's decision in Padilla v. Kentucky does not apply retroactively to a conviction that was final at the time Padilla was decided, including Defendant's conviction. View "State v. Garcia" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree rape and two counts of sexual contact with a child under age sixteen. Defendant was sentenced to fifty years incarceration for each of the first-degree rape convictions and fifteen years for each of the sexual contact convictions, with the sentences to run concurrently. Defendant appealed, arguing, among other things, that the indictment was duplicitous, and therefore, his right to jury unanimity was violated. The Supreme Court affirmed, holding (1) the trial court did not commit plain error in failing to strictly comply with the "either or rule" by either requiring the State to specifically elect the acts it would rely on at trial or by giving a unanimity instruction because the jury was ultimately informed of the unanimity requirement; (2) sufficient evidence supported both of Defendant's sexual contact convictions, but the evidence presented at trial was only sufficient to support one of Defendant's first-degree rape convictions; and (3) the sentences imposed by the trial court did not violate Defendant's Eighth Amendment right against cruel and unusual punishment. View "State v. Brende" on Justia Law

M.E.H. alleged she was kidnapped and raped by Defendant in 2000. The charges against Defendant were dismissed when DNA testing failed to implicate him. In 2008, the case was reopened, and the evidence obtained in 2000 was retested using a new method of DNA testing, which revealed the presence of Defendant's DNA. Defendant was again indicted, and a part II information was filed charging Defendant as a habitual offender. The jury found Defendant guilty of rape in the second and third degree and related charges. In a separate trial, the jury found Defendant was a habitual offender. The Supreme Court reversed, holding that the trial court (1) did not abuse its discretion in admitting evidence of an incident involving another alleged victim as other acts evidence; (2) did not violate Defendant's right to confrontation by admitting testimony regarding the results of the DNA testing performed in 2008 and 2011, even though some steps of the testing were performed by nontestifying analysts; but (3) because the State's filing of an amended part II information effectively dismissed the original part II information, the State's dismissal of the amended part II information left the trial court without jurisdiction over the habitual offender proceedings. Remanded for resentencing. View "State v. Medicine Eagle" on Justia Law