Justia Constitutional Law Opinion Summaries

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

The Supreme Court affirmed the judgment of the trial court convicting Defendant of second-degree murder and sentencing him to forty years in prison, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) as concerning the prosecutor's effort to conceal the State's involvement in Defendant's transfer proceedings, the circuit court properly exercised its discretion to neutralize any error; (2) the circuit court acted within its discretion to denying Defendant's motion for mistrial; (3) viewed in their entirety, the instructions given to the jury correctly stated the applicable law; (4) the exercise of the circuit court's discretion did not contravene Defendant's right to present a complete defense; and (5) Defendant's sentence could not be described as grossly disproportionate to his crime. View "State v. Black Cloud" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree manslaughter and aggravated assault and sentencing him to life imprisonment, holding that Defendant's sentence did not violate the Eighth Amendment.Defendant pled guilty to first-degree manslaughter and aggravated assault. The circuit court sentenced Defendant to life without the possibility of parole for first-degree manslaughter and to a term of fifteen years for aggravated assault to run concurrently with his life sentence. Defendant appealed, arguing that his life sentence constituted cruel and unusual punishment and that the circuit court abused its discretion by imposing a life sentence without the possibility of parole. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion. View "State v. Caffee" on Justia Law

The Supreme Court reversed the order of the circuit court suppressing statements made by Defendant during the execution of a search warrant, holding that the circuit court erred in concluding that Defendant's statements to a law enforcement officer during the execution of a search warrant were involuntarily made.Defendant was indicted for one count each of rape in the third degree and sexual contact with a person incapable of consenting. Defendant filed a motion to suppress the statements he made to law enforcement, arguing that his statements were obtained in violation of Miranda v. Arizona, 384 U.S. 436 (1996). The circuit court granted the motion, concluding that Defendant's statements were involuntarily made under the Due Process Clause. The Supreme Court reversed, holding that, based on a review of the totality of the circumstances, the circuit court erred in concluding that Defendant's statements to law enforcement were involuntarily made. View "State v. Ghebre" on Justia Law

In a previous decision involving a reporter’s request for information concerning an investigation involving Sanford, the South Dakota Supreme Court held that SDCL 23A-35-4.1 permits a circuit court to “seal the contents of an affidavit in support of a search warrant upon a showing of reasonable cause, but only until the investigation is terminated or an indictment or information is filed.” The court may not prohibit the public disclosure of other specific records nor of the fact that a search warrant affidavit has been filed.” Certain personally identifying information within court records must be redacted as a matter of course.Following the completion of the state’s criminal investigation, the circuit court unsealed the search warrant affidavits related to the investigation. Sanford challenged the denial of his request to inspect and participate in redacting the affidavits before the records were unsealed. The South Dakota Supreme Court affirmed. The circuit court properly applied the provisions of SDCL 15-15A-13 and 23A-35-4.1 and thoroughly considered the statutory and constitutional grounds asserted by Sanford with respect to information that could conceivably be contained in the affidavits. The court appropriately exercised its discretion to “decide whether there [were] sufficient grounds to prohibit access” to the contents of the affidavits. View "Matter Of Implicated Individual" on Justia Law