Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of simple assault and kidnapping, holding that the trial court did not err in the proceedings below and that Defendant's sentence was not unconstitutional under the Eighth Amendment.Specifically, the Court held (1) the circuit court did not err when it denied Defendant's motion for a mistrial for an alleged Brady violation; (2) the circuit court did not abuse its discretion when it denied Defendant's motion for a mistrial; (3) Defendant was not denied a fair trial due to cumulative errors; and (4) Defendant's sentence was not grossly disproportionate or excessive. View "State v. Delehoy" on Justia Law

The Supreme Court affirmed the decision of the circuit court affirming the magistrate judge's denial of Defendant's motion to suppress evidence obtained during a vehicle stop, holding the magistrate judge did not err by concluding that the stop was justified under the community caretaker exception.Defendant was convicted in magistrate court of driving under the influence. Defendant appealed the denial of his motion to suppress all evidence and statements obtained during the traffic stop, arguing that the police officer lacked reasonable suspicion of criminal activity. The Supreme Court affirmed, holding that the officer was acting in his community caretaking role when he stopped Defendant's vehicle in the parking lot, and the officer provided specific and articulable facts supporting his decision to stop Defendant's vehicle. View "State v. Short Bull" on Justia Law

The Supreme Court dismissed this appeal from the habeas court's denial of Appellant's petition for writ of habeas corpus for lack of jurisdiction, holding that the certificate of probable cause issued by the circuit court was inadequate.Appellant was found to have violated the terms of his probation and forced to serve his sentence with credit for time already served. Thereafter, Appellant filed a petition for writ of habeas corpus, alleging violations of his rights to due process and effective assistance of counsel. The habeas court denied the petition after a trial and filed an order for issuance of certificate of probate cause. Appellant appealed. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that the habeas court's order for issuance of certificate of probable cause was insufficient to render jurisdiction to this Court. View "Wright v. Young" on Justia Law

The Supreme Court affirmed Defendant’s convictions for first-degree robbery and aiding, abetting, or advising first-degree robbery stemming from two separate cases, holding that any error in the proceedings below was harmless.Specifically, the Court held (1) the circuit court did not by denying Defendant’s motion to dismiss the indictments for violation of his statutory and constitutional rights to a speedy trial; (2) Defendant’s waiver of Miranda rights and subsequent statements were voluntary, knowing, and intelligent; and (3) although Defendant invoked his right to an attorney, his unambiguous request occurred after he had confessed to the crimes, and therefore, the detectives’ error in continuing the interview after that point was harmless, and the circuit court’s failure to exclude Defendant’s post-invocation statements was also harmless. View "State v. Two Hearts" on Justia Law

The Supreme Court affirmed Defendant’s sentence, imposing in connection with his conviction of second-degree rape, of forty years in the state penitentiary, with five years suspended, to run consecutive to the prison term Defendant was currently serving in Iowa for offenses involving the same victim, holding that the sentence was not cruel and unusual in violation of the Eighth Amendment.Specifically, the Supreme Court held (1) after weighing the gravity of the offense against the sentence Defendant received, the circuit court did not violate Defendant’s constitutional rights by imposing a sentence within the authorized fifty-year maximum; and (2) the circuit court did not abuse its discretion in sentencing Defendant. View "State v. Yeager" on Justia Law

The Supreme Court affirmed the circuit court’s judgment convicting Defendant of first-degree rape, multiple counts of sexual contact with a child, and possessing, manufacturing, or distributing child pornography, holding that the circuit court did not violate Defendant’s right to a public trial when it ordered the partial closure of the courtroom during the minor victim’s testimony.On appeal, Defendant argued that the circuit court erred in partially closing the courtroom in violation of his Sixth Amendment right to a public trial and that the court erred in denying his motion to suppress his non-custodial statement to a law enforcement officer. The Supreme Court affirmed, holding (1) there was no violation of Defendant’s Sixth Amendment right to a public trial; and (2) the absence of any custodial interrogation rendered Defendant’s second argument unsustainable under Miranda v. Arizona, 384 U.S. 436 (1996), and Edwards v. Arizona, 451 U.S. at 485-85 (1990). View "State v. Uhre" on Justia Law

The Supreme Court affirmed Defendant’s conviction of first-degree felony murder, commission of a felony while armed with a firearm, and burglary in the first degree, holding that the circuit court properly denied Defendant’s motion to suppress and did not err by refusing to compel specific performance of a plea agreement.On appeal, Defendant argued that his statements to law enforcement during a custodial interrogation should have bene suppressed because they were obtained in violation of his right to counsel and right against self-incrimination. Defendant further claimed that the circuit court erred in denying his motion for specific performance of the plea agreement that he alleged would have allowed him to plead guilty to manslaughter. The Supreme Court affirmed, holding (1) the admission of the evidence that was the subject of the motion to suppress was harmless error even if the statements had been unlawfully obtained; and (2) Defendant failed to show an enforceable plea agreement existed, and therefore, the circuit court properly denied Defendant’s motion for specific performance of the plea agreement. View "State v. Lewandowski" on Justia Law

The Supreme Court affirmed Defendant’s judgment of conviction and sentence for third-degree rape, holding that the circuit court did not err in denying Defendant’s motion to suppress evidence obtained from a warrantless search of his garage, holding that Defendant was not seized for Fourth Amendment purposes at the beginning of his encounter with police deputies and that his consent to search the garage was voluntary.On appeal, Defendant asserted that he was unreasonably seized by deputies before the search took place, and therefore, any consent give to search the garage after the seizure was not voluntary. The Supreme Court disagreed, holding that the deputies’ actions were reasonable, Defendant was not seized as soon as the encounter began, and Defendant’s consent to search the garage was voluntary. View "State v. Rolfe" on Justia Law

The Supreme Court affirmed Defendant’s conviction of second-degree murder, holding that the circuit court did not err in denying Defendant’s motion to suppress evidence obtained as a result of an investigatory stop.Prior to trial, the circuit court denied Defendant’s motion to suppress the evidence obtained as a result of the stop, concluding that the arresting law enforcement officer had reasonable suspicion to initiate the investigatory stop. The Supreme Court affirmed, holding that the officer’s suspicion was not grounded on a mere hunch, that the officer articulated facts that supported the quantum of suspicion necessary to initiate an investigatory stop, and that, under the totality of the circumstances, the investigatory stop was based on reasonable suspicion within the meaning of the Fourth Amendment. View "State v. Chase" on Justia Law

The Supreme Court affirmed the judgment of the circuit court entering an amended judgment of conviction ordering Defendant’s sentences to run concurrently to his corresponding federal sentences, holding that Defendant had no Sixth Amendment right to counsel in the circuit court proceeding to correct his sentences.Defendant pleaded guilty to kidnapping and assault. Defendant was sentenced to life imprisonment for the kidnapping and thirty years for the assault. The circuit court ordered the sentences to run consecutively to corresponding federal sentences Defendant had received for the same offenses. The Supreme Court reversed and remanded the case for resentencing, holding that a South Dakota state court may not impose a consecutive sentence in state court when a defendant has been sentenced for the same offenses in federal court. After Defendant was resentenced, he argued that the circuit court’s failure to provide court-appointed counsel in the sentence correction proceeding violated his Sixth Amendment right to counsel. The Supreme Court disagreed, holding that the sentence correction proceeding was not a critical stage in which Defendant had a Sixth Amendment right to court-appointed counsel. View "State v. Red Kettle" on Justia Law