Justia Civil Rights Opinion Summaries

Articles Posted in South Dakota Supreme Court
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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

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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