Justia Civil Rights Opinion Summaries

Appellant Mil Hirning pleaded guilty to unauthorized possession of a controlled substance and admitted to being a habitual offender. Hirning made the plea after Hirning's trial counsel withdrew from representing him and Hirning proceeded pro se. On appeal, Hirning argued that his waiver of counsel was not voluntary, knowing, and intelligent. The Supreme Court reversed Hirning's convictions and sentence, (1) finding that Hirning was not warned of the dangers of self-representation, and (2) holding that the record did not indicate circumstances from which the Court could find Hirning was aware of the danger and made a voluntary, knowing, and intelligent waiver. Remanded.

Petitioner Dale Guthmiller was convicted of criminal pedophilia and sentenced to life in prison. Petitioner subsequently petitioned the circuit court for a writ of habeas corpus, alleging, among other things, that the trial judge made improper comments during the trial, violating Petitioner's constitutional right to a fair trial. The habeas court granted Petitioner's writ on reconsideration, (1) concluding that the trial judge's comments created a structural error negating Petitioner's requirement to establish prejudice, and (2) retracting its earlier ruling that trial counsel's failure to object was not prejudicial. The Supreme Court reversed, holding (1) the trial judge's comments did not constitute a structural error, and (2) despite defense counsel's failure to object to the judge's improper remarks, Petitioner did not meet his burden of showing that the jury's verdict would reasonably likely have been different absent trial counsel's errors.

Over a period of two years, the City of Sioux Falls issued Daniel Daily four citations for a concrete extension to his driveway. Daily appealed each of the citations, but a hearing was held only on the final two citations received. Daily then initiated a declaratory judgment action against the City. The trial court ultimately concluded that the City's administrative appeals process, both as written and as applied, and the City's enforcement of its zoning ordinances violated Daily's constitutional rights to procedural due process and equal protection. The Supreme Court affirmed, holding (1) because the hearing examiner in this case did not hold the City to its burden of proof, the City's administrative appeals process deprived Daily of a protected property interest without due process of law; and (2) the hearing examiner's application of the rules of evidence deprived Daily of a fair hearing.

Kenneth Stark, a registered sex offender, was convicted of loitering in a community safety zone in violation of S.D. Codified Laws 22-24B-24. On appeal, the Supreme Court affirmed, holding (1) the state statutes prohibiting sex offenders from loitering in community safety zones are constitutional; (2) the trial court did not err by allowing the State to amend the information to include the correct location of Stark's prior felony conviction; (3) there was sufficient evidence to establish that Stark's primary purpose for remaining in the community safety zones was to observe or contact minors; and (4) the trial court did not abuse its discretion by admitting evidence that an individual in a white mini-van registered to Stark was seen in a community safety zone the day before the charged conduct occurred.

Matt Onnen was terminated from the position of registrar at Southeast Technical Institute (STI), an entity of the Sioux Falls School District, after STI officials found several degrees or diplomas had been approved and awarded by Onnen to students who had not earned them, and several students entitled to a degree or diploma had not received one. The Sioux Falls School Board affirmed the decision. Onnen appealed the District's and Board's decision to circuit court, which affirmed the District. On appeal, the Supreme Court affirmed, holding (1) the district court did not err in concluding that the District's decision was not arbitrary and capricious or an abuse of discretion; (2) because Onnen was not a teacher at STI, he was not entitled to sixty days' notice before termination, and therefore Onnen was not denied procedural due process when he was terminated; and (3) the district court did not abuse its discretion in denying Onnen's motion for a new trial.

Defendant William Jensen was charged with fourth offense driving under the influence. He filed a motion to strike one of his three prior driving under the influence convictions, arguing that because the magistrate court relied on a statement of rights form to establish the voluntariness of his guilty plea during that prior hearing, that prior conviction was invalid for sentence enhancement purposes. The trial court denied Jensen's motion to strike, concluding that the statement of rights form was an adequate record of voluntariness. Jensen appealed. The Supreme Court affirmed, holding (1) because Jensen did not demonstrate prejudice, his challenge to his prior driving under the influence conviction was not proper for the Court's consideration; and (2) Jensen did not demonstrate that the magistrate court's failure to personally canvass him to establish the voluntariness of his plea violated his due process rights.

Defendant Ivan Good Plume was found guilty of aggravated assault and of being a habitual offender and was sentenced to eighteen years in prison. On appeal, defendant asserted (1) that the sentencing judge, in referring to a pattern of drunken violence by Good Plume as "going native," evinced his personal bias against defendant and used race as a sentencing factor, thus violating defendant's federal and state due process rights; and (2) the judge abused his discretion in admitting into evidence a letter defendant wrote without considering the requirements of S.D. R. Evid. 404(b) before admitting it. The Supreme Court affirmed, holding (1) defendant did not meet his burden of making a specific and substantial showing that a racial or personal bias was used as an aggravating factor in his sentence, and (2) the letter was admitted not to prove defendant engaged in other wrongs, crimes, or acts but as res gestae evidence necessary to prove intent.