Justia Civil Rights Opinion Summaries

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

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

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

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

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

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

The Supreme Court affirmed Defendant's conviction for first-degree burglary and grand theft, holding that the circuit court did not err when it denied Defendant's motion to suppress and when in denied Defendant's motion for expert fingerprint testing.Defendant filed a motion to suppress gun evidence that was returned to the owner before trial, arguing that the State would be unable to establish a proper chain of custody. The circuit court denied the motion to suppress. The Supreme Court affirmed, holding (1) although the law enforcement officers and the prosecutor did not comply with statutory standards before releasing the evidence to its owner, the circuit court did not err in denying the motion to suppress because the guns did not possess apparent exculpatory value; and (2) even if the circuit court abused its discretion by denying Defendant's request for fingerprint testing, there was no prejudice. View "State v. Zephier" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree rape and sexual contact involving a second victim, holding that Defendant's allegations of error were unavailing.Specifically, the Supreme Court held (1) the circuit court did not abuse its discretion by allowing evidence of Defendant's two prior alleged sexual assaults; (2) the admission of other act evidence did not violate Defendant's constitutional rights under the Double Jeopardy and Due Process Clauses; (3) the circuit court did not abuse its discretion when it denied Defendant's motion for a mistrial; (4) there was sufficient evidence to support the conviction; (5) the circuit court erred in admitting forensic laboratory reports by affidavit without affording Defendant the opportunity to cross-examine the analysts who conducted the testing and authored the reports, but the error was not prejudicial; and (6) Defendant's sentence did not violate the Eighth Amendment. View "State v. Taylor" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's motion to suppress evidence obtained as a result of his encounter with police, holding that the circuit court properly denied the motion to suppress.Defendant was charged with possession of controlled substances, a loaded firearm while intoxicated, marijuana, and drug paraphernalia. Defendant filed a motion to suppress evidence obtained from a stop of his person on the basis that it violated the Fourth Amendment. The circuit court denied the motion, concluding that the search was done in accordance with Terry v. Ohio, 392 U.S. 1 (1968) and its progeny. The Supreme Court affirmed, holding (1) under the totality of the circumstances, the officers had reasonable suspicion to stop Defendant; and (2) therefore, the circuit court did not err by denying Defendant's motion to suppress. View "State v. Williams" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of second-degree murder and sentencing him to ninety years in prison, holding that Defendant's discretionary sentence did not offend the Eighth Amendment's prohibition against cruel and unusual punishment.Defendant pled guilty to second-degree murder. He was seventeen years old when he committed the crime. The circuit court sentenced Defendant to ninety years in prison, making him eligible for parole at age sixty-two. On appeal, Defendant argued that his sentence was unconstitutional because it violated categorical Eighth Amendment sentencing restrictions for juveniles and because it was disproportionately harsh. The Supreme Court disagreed, holding (1) because the court did not sentence Defendant to a mandatory life sentence and sufficiently considered his youth when fashioning his sentence, there was no Eighth Amendment violation; and (2) Defendant did not meet the initial requirement to show that his sentence was grossly disproportionate to his crime. View "State v. Quevedo" on Justia Law