Justia Constitutional Law Opinion Summaries

Donika Rae Gonzales was convicted in 2014 by a jury of first-degree manslaughter and aggravated assault for beating her boyfriend’s four-year-old son to death. Gonzales filed a petition for a writ of habeas corpus, arguing that the jury district, which included residents from both Brule and Buffalo Counties, diluted the percentage of prospective Native American jurors, violating her constitutional rights. She also claimed ineffective assistance of counsel for her attorney’s failure to introduce certain evidence at trial. The habeas court found that the jury district violated both federal and state constitutions and reversed her conviction without addressing the ineffective assistance claims.The Circuit Court of the First Judicial Circuit initially sent jury questionnaires to only Buffalo County residents, but due to an inadequate number of responses, included Brule County residents as well, based on a 2011 standing order. Gonzales agreed to hold the trial in Brule County and use a combined jury pool from both counties. The jury pool consisted of 236 jurors, with 22% Native American representation, compared to 29% in the combined population of the two counties. Gonzales appealed her conviction, but it was summarily affirmed by the South Dakota Supreme Court in 2016.The South Dakota Supreme Court reviewed the case and reversed the habeas court’s decision. The court held that the use of a jury district comprising Buffalo and Brule Counties did not violate the South Dakota Constitution’s requirement for a trial by a jury of the “county or district” where the offense occurred. The court also found that Gonzales failed to establish a violation of the Sixth Amendment’s fair cross-section requirement, as the absolute disparity in Native American representation was only 7%, below the constitutional threshold. Consequently, Gonzales’ ineffective assistance claims were also deemed without merit, and the order granting habeas relief was vacated. View "Gonzales v. Markland" on Justia Law

In the early morning of March 19, 2022, Quincy Bear Robe, his girlfriend, and her friends were in a hotel room when Myron Pourier and his friends entered uninvited. An altercation ensued, during which Bear Robe and Isaac Runningshield discharged their guns, resulting in Pourier's death from two gunshot wounds. Bear Robe was found nearby with a .40 caliber handgun and later bragged about the shooting to a friend. He was indicted on charges including second-degree murder and first-degree murder but accepted a plea agreement to plead guilty to first-degree manslaughter.The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, accepted Bear Robe's guilty plea and ordered a presentence investigation report (PSI). The PSI noted Bear Robe's lack of prior criminal record, his young age, and several mitigating factors from his childhood, including mental health issues and a chaotic home environment. Despite these factors and letters of support from family and community members, the circuit court sentenced Bear Robe to 75 years in the penitentiary without any time suspended.The Supreme Court of the State of South Dakota reviewed the case. Bear Robe argued that the circuit court abused its discretion by focusing too heavily on general deterrence and not adequately considering mitigating evidence. He also contended that the sentence was cruel and unusual under the Eighth Amendment. The Supreme Court held that the circuit court did not abuse its discretion, as it had thoroughly considered Bear Robe's character and history, and the sentence was within the permissible range. The court also found that the 75-year sentence was not grossly disproportionate to the gravity of the offense of first-degree manslaughter. The Supreme Court affirmed the circuit court's decision. View "State v. Bear Robe" on Justia Law

Danny Washington was convicted by a jury on multiple charges, including first-degree kidnapping, injury to personal property, and several counts of aggravated and simple assault. The charges stemmed from incidents involving his then-girlfriend, J.B., in October 2021. Washington allegedly assaulted J.B., damaged her vehicle, and forcibly confined her with a firearm, leading to his arrest and subsequent indictment on eight counts.The Circuit Court of the Second Judicial Circuit in Minnehaha County, South Dakota, presided over the trial. Washington filed several pretrial motions, including motions to exclude references to his parole status and to prevent the use of the term "victim" in court. The court granted these motions but denied his request for a personal copy of the discovery. During the trial, the jury found Washington guilty on all counts. Washington later filed a motion for a new trial, citing ineffective assistance of counsel and other trial errors, which the court denied. He was sentenced to 100 years for kidnapping, with additional concurrent and consecutive sentences for other charges.The Supreme Court of South Dakota reviewed the case. Washington argued ineffective assistance of counsel, insufficient evidence for the kidnapping conviction, cumulative trial errors, discrepancies between the oral and written sentences, and improper multiple convictions for aggravated assault. The court declined to address the ineffective assistance claim on direct appeal, noting the need for a more developed record. It found sufficient evidence to support the kidnapping conviction and determined that the alleged trial errors did not cumulatively deny Washington a fair trial. The court clarified that the written sentence, which suspended 60 years of the 100-year kidnapping sentence, controlled over any ambiguous oral pronouncements. Finally, the court held that entering multiple convictions for a single statutory offense arising from the same act violated double jeopardy principles, but found no plain error due to the lack of clear precedent. The court affirmed the lower court's decisions. View "State v. Washington" on Justia Law

A Sturgis police officer stopped a vehicle for a headlamp violation. The driver, who lacked identification, was found with methamphetamine and drug paraphernalia and was arrested. Wanda Edwards, the passenger, refused to hand over her purse during a vehicle search. Law enforcement forcibly took and searched the purse, finding methamphetamine and drug paraphernalia. Edwards was charged with possession of a controlled substance, possession of marijuana, and obstructing a law enforcement officer. She moved to suppress the evidence found in her purse, but the motion was denied, and she was convicted.The Circuit Court of the Fourth Judicial Circuit in Meade County, South Dakota, denied Edwards' motion to suppress, ruling that the search of the vehicle and its contents, including Edwards' purse, was lawful as it was incident to the driver's arrest. The court concluded that the purse was a container within the vehicle at the time of the arrest, and Edwards' attempt to remove it did not change its status.The Supreme Court of the State of South Dakota reviewed the case. Edwards argued that the search of her purse violated her Fourth Amendment rights, citing that probable cause to search a vehicle does not extend to a passenger's person. The State argued that the search was justified under the automobile exception and as a search incident to arrest. The court held that the search of Edwards' purse was lawful under the automobile exception, as probable cause to search the vehicle extended to all containers within it, including personal belongings of passengers. The court affirmed the lower court's decision, upholding Edwards' convictions. View "State v. Edwards" on Justia Law

Cody Heer was convicted of multiple drug-related offenses after selling methamphetamine to a confidential informant in a Walmart parking lot in Sioux Falls, with his child present. Heer was indicted on charges of distributing a controlled substance, possession of a controlled substance, and causing a child to be present where methamphetamine is distributed. The State also filed a habitual offender information due to Heer’s prior felony convictions.Initially represented by court-appointed counsel, Heer moved to represent himself after his request for substitute counsel was denied. The Circuit Court of the Second Judicial Circuit in Minnehaha County granted his motion for self-representation but appointed his former attorney as standby counsel. Heer did not object to this arrangement or to the presence of standby counsel at trial. Heer conducted his defense, including making motions, cross-examining witnesses, and delivering closing arguments. The jury found Heer guilty on all counts, and he was sentenced to fifteen years in prison for the distribution conviction, with additional suspended sentences for the other charges.The Supreme Court of the State of South Dakota reviewed Heer’s appeal, where he argued that his Sixth Amendment right to self-representation was violated by the appointment and presence of standby counsel. Heer also claimed that the prosecutor’s statements during closing arguments constituted improper vouching, amounting to plain error. The court held that the appointment of standby counsel was permissible and did not violate Heer’s rights, as standby counsel did not interfere with his control over the case. The court also found no merit in Heer’s claims of improper vouching, concluding that the prosecutor’s statements were fair characterizations of the evidence and did not affect the trial’s outcome. The court affirmed Heer’s convictions and sentences. View "State V. Heer" on Justia Law

SCS Carbon Transport, LLC (SCS) plans to develop a pipeline network to transport carbon dioxide (CO2) through South Dakota. Several landowners (Landowners) along the proposed route refused to allow SCS pre-condemnation survey access, which SCS claims is authorized by SDCL 21-35-31. Landowners sued in both the Third and Fifth Judicial Circuits, seeking declaratory and injunctive relief to prevent the surveys. These proceedings resulted in a consolidated appeal from six lawsuits filed by Landowners and one by SCS.The Third Circuit granted SCS summary judgment, determining that SCS was a common carrier and that SDCL 21-35-31 was constitutional. The Fifth Circuit also granted SCS summary judgment, adopting the Third Circuit’s reasoning. Landowners appealed, arguing that SCS is not a common carrier, CO2 is not a commodity, and that SDCL 21-35-31 violates the takings and due process clauses of the state and federal constitutions.The Supreme Court of South Dakota reversed the circuit courts’ grants of summary judgment on the common carrier issues. The court held that SCS’s ability to conduct pre-condemnation surveys depends on whether it is a common carrier vested with the power of eminent domain. The record did not demonstrate that SCS is holding itself out to the general public as transporting a commodity for hire. The court also found that the circuit courts abused their discretion in denying Landowners’ request for further discovery.The court further held that SDCL 21-35-31 only authorizes limited pre-condemnation standard surveys, which are minimally invasive superficial inspections. The statute, as strictly interpreted, does not violate the federal or state constitutions. The court concluded that any actual damage caused by the surveys must be justly compensated, with the amount determined by a jury. The case was remanded for further proceedings consistent with this opinion. View "Strom Trust v. SCS Carbon Transport, LLC" on Justia Law

The case involves James Joseph Lanpher, Jr., who pleaded guilty to two counts of aggravated assault against a law enforcement officer and admitted to being a habitual offender. The charges stemmed from a dangerous high-speed chase during which Lanpher repeatedly fired weapons at pursuing officers. The circuit court sentenced Lanpher to serve two concurrent life sentences to run consecutively to sentences he was already serving for other offenses. Lanpher appealed, claiming his sentence was cruel and unusual in violation of the Eighth Amendment and was an abuse of the circuit court’s discretion.The case was previously reviewed by the circuit court of the Third Judicial Circuit, Lake County, South Dakota. The court found Lanpher guilty and sentenced him to two concurrent life sentences, to be served consecutively to sentences he was already serving for other offenses.The Supreme Court of the State of South Dakota reviewed the case and affirmed the decision of the lower court. The court found that Lanpher's sentence did not constitute cruel and unusual punishment in violation of the Eighth Amendment. The court also found that the circuit court did not abuse its discretion in the imposition of Lanpher’s sentence. The court noted that Lanpher's violent criminal history and demonstrated disregard for human life justified the severity of his sentence. View "State v. Lanpher" on Justia Law

The case involves Keaton Van Der Weide, who was accused of raping S.O., his on-and-off partner and mother of his child. S.O. alleged that Van Der Weide sexually assaulted her after she returned home from a night out, while Van Der Weide maintained that the encounter was consensual and involved the use of sex toys. He was charged with second-degree rape.Before trial, Van Der Weide sought to introduce evidence of the sex toys and text messages between himself and S.O. The circuit court ruled that unless the State alleged that a toy was used during the rape, Van Der Weide could not proffer evidence of the same. The court allowed the State to cross-examine Van Der Weide based on other texts surrounding the excerpted messages. Van Der Weide was found guilty and appealed, arguing that the court abused its discretion in excluding evidence of the sex toys and allowing the State to cross-examine based on unadmitted text messages.The Supreme Court of the State of South Dakota reversed the decision, finding that the circuit court had erred in excluding Van Der Weide's testimony regarding the sex toys, violating his constitutional right to testify in his defense. The court could not conclude that preventing the jury from weighing this important context was harmless beyond a reasonable doubt. Therefore, Van Der Weide was entitled to a new trial. View "State v. Van Der Weide" on Justia Law

In the case before the Supreme Court of the State of South Dakota, a Minnesota-based company, Ellingson Drainage, Inc., was charged a use tax by the South Dakota Department of Revenue (DOR) after an audit revealed Ellingson had not paid use tax on equipment used in South Dakota but purchased elsewhere. Ellingson challenged the constitutionality of the tax in an administrative appeal, which was dismissed. The company then appealed to the circuit court, which affirmed the imposition of the tax, holding it did not violate the Due Process Clause of the Fourteenth Amendment or the Interstate Commerce Clause. Ellingson appealed this decision and the Supreme Court of the State of South Dakota also affirmed the imposition of the tax.The Court determined that the use tax, imposed under SDCL 10-46-3, met all four prongs of the Complete Auto test, which is used to determine if a tax violates the Interstate Commerce Clause. The Court found that Ellingson had a sufficient connection to South Dakota, the tax was fairly related to benefits provided to the taxpayer, the tax did not discriminate against interstate commerce, and the tax was fairly apportioned. Moreover, the Court concluded that the use tax did not violate the Due Process Clause of the Fourteenth Amendment, as Ellingson had a sufficient connection to South Dakota and the statute was rationally related to South Dakota values.The Court rejected Ellingson's argument that the tax was unfairly disproportionate to the extent of the equipment’s usage in South Dakota, stating that "use is use" and that the provisions of SDCL 10-46-3 do not contemplate a formula by which to measure use. The Court concluded that such a change is not a judicial one, but rather one better suited to the formulation of public policy by the Legislature. View "Ellingson Drainage v. Dep’t Of Revenue" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying the State's motion to dismiss the second petition for a writ of habeas corpus filed by David Lee in 2004, holding that Lee's claim for habeas relief must be denied.Lee brought his second habeas corpus petition in 2004, alleging that his habeas counsel was ineffective for failing to seek a certificate of probable cause in his first habeas corpus proceeding. It wasn't until 2019, however, that Lee served the State with the provisional writ. The State moved to dismiss the writ, arguing that after the expiration of the statutory 30-day period for filing a motion for a certificate of probable cause under S.D. Codified Laws 21-27-18.1, the court did not have the authority to issue a certificate of probable cause. The circuit court denied the motions to dismiss. The Supreme Court reversed, holding (1) Lee had no right to appeal absent a certificate of probable cause issued by the habeas court or a member of the Supreme Court, and Lee had no right to a certificate of probable cause; and (2) even if Lee's habeas counsel was ineffective, it did not deprive Lee of any constitutional or statutory right that may be vindicated in a habeas corpus proceeding. View "Lee v. Weber" on Justia Law