Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was found guilty of possession of marijuana and possession of drug paraphernalia. Defendant appealed, asserting that the jury had insufficient evidence to find that he possessed the marijuana found in the apartment he resided in. Defendant's girlfriend was listed as the apartment's only tenant. The Supreme Court affirmed, holding that the State produced sufficient evidence to sustain the conviction, as (1) Defendant had at least joint control over the dresser where the marijuana was found and thus joint control over the marijuana; and (2) Defendant's had a knowledge of the specific character and location of the marijuana. View "State v. Wheeler" on Justia Law

The State charged Defendant with bigamy in violation of S.D. Codified Laws 22-22A-1. Defendant moved to dismiss the information, arguing that the State failed to state a public offense. Specifically, Defendant argued that because a bigamous marriage is void ab initio under S.D. Codified Laws 25-1-8, he was never legally married the second time, and thus, it was legally impossible to prosecute him for bigamy. The trial court accepted this argument and dismissed the case. The Supreme Court reversed, holding that in order to give meaning and effect to the enactment of section 22-22A-1, bigamy is committed when a person enters into a purported marriage contract or relationship at a time when the person already has a living spouse. Remanded. View "State v. Clements" on Justia Law

Defendant was charged with numerous crimes, including grand theft. Defendant entered into an agreement with the State in which the State agreed to defer prosecution of the grand theft charge if Defendant pleaded guilty to other charges and complied with additional conditions, one of which required Defendant to plead guilty to grand theft if he violated any of the other conditions of the agreement. Defendant later violated some of the conditions of the agreement, and consequently, the State re-filed the grand theft charge against Defendant. Defendant filed a motion to exercise his right to a jury trial. The circuit court denied the motion based on the terms of the agreement. Defendant subsequently pleaded guilty to grand theft and was sentenced. The Supreme Court reversed, holding (1) the portion of the agreement requiring Defendant to plead guilty to grand theft was unenforceable because it unconstitutionally deprived Defendant of his right to voluntarily enter his choice of plea on the grand theft charge; and (2) because that portion of the agreement was unenforceable, the circuit court erred in determining that Defendant was bound by that portion of the agreement and in subsequently denying Defendant's motion to exercise his right to a jury trial. View "State v. Fox" on Justia Law

A law enforcement officer stopped a vehicle driven by Shane Erwin for making an illegal left turn. After engaging in routine traffic stop questioning, the officer became suspicious and walked his drug-sensing dog around Defendant's vehicle. Drugs and drug paraphernalia were later found in the vehicle. Shane and his father, Richard Erwin, who was traveling in the vehicle, were both arrested. The Erwins moved to suppress evidence, alleging an illegal stop. The trial court granted the motion. The Supreme Court reversed, holding that the officer had probable cause to stop the Erwins because he witnessed a violation of S.D. Codified Laws 32-26-18, which requires that a left turning vehicle turn into the left most lawfully available lane. Remanded. View "State v. Erwin" on Justia Law

After a jury trial, Defendant was convicted of sexual contact with a child under the age of sixteen. Defendant appealed, arguing that his arraignment was inadequate and that the trial court erred in denying his motion for a new trial. The Supreme Court affirmed, holding (1) because Defendant had sufficient notice of the charge against him, pleaded not guilty, exercised his rights, and had an adequate opportunity to defend himself at trial, there was no error in the arraignment; and (2) Defendant waived his argument that the trial court erred in failing to enter a specific finding that the minor victim was a competent witness, and therefore, the trial court did not err in denying Defendant's motion for a new trial. View "State v. Anderson" on Justia Law

A deputy sheriff stopped a pickup truck because he did not see the vehicle's temporary license permit on the rear window. Defendant, the driver, was subsequently arrested for DUI. Defendant filed a motion to suppress the evidence obtained from the stop. The circuit court granted the motion, concluding that the deputy unconstitutionally extended the scope of the stop by initiating contact with the driver when the deputy could have first confirmed that the temporary license permit was valid. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the circuit court did not err when it ruled that the initial stop of Defendant's pickup was based on reasonable and articulable suspicion that the vehicle was without a license; (2) when an officer stops a vehicle based on objectively reasonable suspicion of illegal activity, and the officer's suspicion is dispelled, the officer may nonetheless approach the driver and explain the mistake; and (3) it was error for the circuit court to suppress the evidence gathered as a result of the stop and to order dismissal of the case. View "State v. Amick" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault. Defendant appealed, alleging multiple errors in his trial. The Supreme Court (1) remanded for further proceedings on a potential Batson violation for the trial court's grant of a preemptory strike of a Native American juror, holding that Defendant established a prima facie case for purposeful discrimination in the preemptory strike, and because the circuit court failed to determine if Defendant proved that the State was motivated by purposeful discrimination, a limited remand was required to allow the circuit court to engage in the missing analysis; and (2) otherwise affirmed. View "State v. Scott" on Justia Law

After a jury trial, Defendant was convicted of first-degree manslaughter by means of a dangerous weapon, vehicular homicide, vehicular battery, and DUI. Defendant was acquitted of two charges of first-degree manslaughter while engaged in the commission of a felony. Defendant appealed, arguing (1) the language "while engaged in the commission of a felony" was prejudicial when referring to the charge of DUI; and (2) the trial court improperly overruled her objections to the admissibility of testimony regarding the kinetic energy of Defendant's vehicle. The Supreme Court reversed and remanded for a new trial, holding (1) because the jury did not convict Defendant on the counts containing the language "while engaged in the commission of a felony," Defendant's argument that she was prejudiced was moot; but (2) the trial court erred when it concluded that the disputed testimony was relevant, and the error was not harmless. View "State v. Kvasnicka " on Justia Law

After a jury trial, Defendant was convicted of possession of one to ten pounds of marijuana. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion for judgment of acquittal, as the evidence was sufficient to sustain the conviction; (2) Defendant's proposed jury instructions were properly denied, as the instructions provided to the jury correctly stated the law and informed the jury; (3) the trial court did not abuse its discretion in denying Defendant's motion to have the jury view his residence; and (4) the trial judge did not abuse his discretion when he did not recuse himself on the basis of impartiality where Defendant provided no objective grounds to conclude the trial judge's impartiality might be reasonably questioned. View "State v. Hauge" on Justia Law

Defendant was retried on multiple rape and sexual contact offenses against his daughter after his 2008 conviction was overturned on direct appeal. After a second jury trial, Defendant was convicted on all charges and was sentenced by the trial court to sixty years in the penitentiary. The Supreme Court affirmed, holding that the trial court did not abuse its discretion by (1) admitting evidence pertaining to Defendant's subornation of perjury conviction, as evidence of Defendant's act of fabricating evidence was relevant to Defendant's consciousness of guilt, and any prejudicial effect was substantially outweighed by the probative value of the evidence; and (2) denying Defendant's motion to dismiss based on a defective indictment, where the indictment was not fatally defective because it was neither duplicitous nor failed to apprise Defendant of the charges against him. View "State v. Fisher" on Justia Law