Justia Constitutional Law Opinion Summaries

Brian Pyle sought a writ of mandamus to compel several South Dakota law enforcement agencies and officials to provide him with investigative records regarding the disappearance and death of his son, Ryan. Ryan was reported missing in August 2020, and his remains were found in November 2020 near the Snake Creek Recreation Area. Pyle alleged that he had made numerous requests for medical records and investigative reports, but had not received any documents. He cited Marsy’s Law in the South Dakota Constitution, asserting that as a victim or relative of a victim, he was entitled to these records.The Circuit Court of the First Judicial Circuit, Charles Mix County, initially issued a peremptory writ requiring the respondents to answer. The State, representing all respondents, moved to quash the writ, arguing that the requested records contained confidential criminal justice information exempt from disclosure by law, and that Pyle had not exhausted administrative remedies for accessing such records. The State also contended that, since law enforcement found no evidence of foul play and concluded no crime had occurred, Marsy’s Law did not apply. After a hearing, in which no testimony or evidence was presented, the circuit court granted the State's motion, quashed the writ, and denied Pyle's application, finding Pyle was not a victim under Marsy’s Law and that no mandatory duty existed to disclose the records.On appeal, the Supreme Court of the State of South Dakota reviewed the circuit court’s decision for abuse of discretion and questions of law de novo. The Supreme Court held that Marsy’s Law requires a crime to have occurred for someone to be considered a victim and to invoke its rights. Because law enforcement determined no crime had been committed, Pyle was not entitled to the records under Marsy’s Law. Further, the Supreme Court found that South Dakota statutes exempt criminal investigative records from mandatory disclosure. The circuit court’s decision was affirmed. View "Pyle v. S.D. Division Of Criminal Investigation" on Justia Law

A residential subdivision in Black Hawk, South Dakota, known as Hideaway Hills, was constructed atop land with a history of both underground and surface gypsum mining. The State of South Dakota, through the South Dakota Cement Plant Commission, purchased the property, conducted surface mining, and reclaimed the land to pasture before selling it at public auction, while retaining subsurface mineral rights. Subsequent private owners and developers, aware of prior mining activity, developed the land into residential lots. Years later, residents began experiencing foundational problems and sinkholes, which culminated in a significant sinkhole event in 2020, leading to evacuation and property devaluation.After previous lawsuits against various parties were dismissed, a class action was brought in the Circuit Court of the Fourth Judicial Circuit, Meade County, against the State and related entities. The plaintiffs alleged inverse condemnation, asserting that the State’s reclamation and retention of subsurface rights amounted to a taking or damaging of private property for public use under the South Dakota Constitution. The circuit court granted summary judgment to the State, holding that the plaintiffs’ claims were, in essence, tort claims barred by sovereign immunity.On appeal, the Supreme Court of the State of South Dakota affirmed the circuit court’s decision. The Supreme Court held that the plaintiffs failed to establish a viable inverse condemnation claim because the alleged governmental actions occurred while the State owned the property, and thus did not implicate “private property.” The Court further found that the State’s activities were not for “public use” within the meaning of the state constitution, as the retained mineral rights did not confer a public right of use. The Supreme Court affirmed summary judgment for the State. View "Morse v. State" on Justia Law

A man was stopped by South Dakota wildlife conservation officers while boating on the Missouri River between South Dakota and Nebraska in July 2024. The officers noticed possible impairment and, after a field sobriety test, arrested him for boating under the influence and other offenses. The events in question took place near the Nebraska shoreline, beyond the centerline of the river’s designed channel.The defendant moved to dismiss the charges in the Magistrate Court of the First Judicial Circuit, Union County, South Dakota, arguing the state lacked jurisdiction because the incident happened on the Nebraska side of the river. After an evidentiary hearing, the magistrate court found that the arrest occurred on the Nebraska side, and concluded that South Dakota’s statutes giving conservation officers jurisdiction to the furthermost shoreline were preempted by the federally approved 1989 South Dakota-Nebraska Boundary Compact, which fixes the state boundary at the centerline of the Missouri River. The magistrate court dismissed the case for lack of jurisdiction.The State of South Dakota sought appellate review. The Supreme Court of the State of South Dakota first determined that the State’s petition for intermediate appeal was timely and that it had appellate jurisdiction. The Supreme Court held that the magistrate court did not abuse its discretion by receiving testimony and evidence to resolve the jurisdictional issue. The Supreme Court further held that, based on federal law and the 1989 Compact, South Dakota does not have concurrent jurisdiction over the Missouri River beyond the centerline of the designed channel unless there is an agreement or reciprocal legislation with Nebraska, which does not exist. As a result, the Supreme Court affirmed the magistrate court’s order dismissing the charges for lack of jurisdiction. View "State v. Ogden" on Justia Law

A police officer in Aberdeen, South Dakota, stopped a driver after observing him make a right turn at an intersection. The officer initiated the traffic stop because he believed the driver had violated a statute requiring a turn signal to be activated for at least 100 continuous feet before turning. The stop led to an arrest for driving under the influence, and a subsequent blood test showed a high blood alcohol concentration. The driver moved to suppress the evidence, arguing that the officer lacked legal justification for the stop because the relevant traffic law did not require a turn signal under the circumstances.The magistrate court held a suppression hearing and denied the motion, finding the statute required use of a turn signal for at least 100 feet before any turn. A court trial on stipulated facts followed, resulting in a conviction for DUI. The driver appealed to the Circuit Court for the Fifth Judicial Circuit, which affirmed the magistrate’s decision. The Circuit Court determined the officer had reasonable suspicion to stop the vehicle based on his observation of what he believed to be a traffic violation, and concluded that the statutory language encompassed the circumstances of the stop.Upon review, the Supreme Court of the State of South Dakota reversed. The Supreme Court held that the statutes governing turn signals require a signal only when another vehicle may be affected by the turn, and that the officer’s belief that a signal was always required was an objectively unreasonable mistake of law. Because the officer did not have reasonable suspicion based on a valid interpretation of the law, the stop was unconstitutional. The Supreme Court reversed the lower courts’ rulings and remanded the case for further proceedings. View "State v. Hawley" on Justia Law

Two Sioux Falls police officers attempted to stop a stolen vehicle driven by a suspect who had absconded from parole and was believed to be armed. During a subsequent foot chase, the suspect allegedly shot at the officers, injuring one, and later exchanged gunfire with other law enforcement before being apprehended. After his arrest, the Minnehaha County State’s Attorney filed criminal charges, and the unredacted names of the two officers appeared in public court documents. The officers, invoking their rights as crime victims under Article VI, § 29 of the South Dakota Constitution (Marsy’s Law), requested that their names and any identifying information be redacted from public filings, citing concerns about potential harassment or targeting.Initially, the officers sought relief through a writ of mandamus, which was denied by a judge outside the circuit, who found that Marsy’s Law and South Dakota statutes provided an adequate remedy within the ongoing criminal proceedings. The officers then intervened directly in the criminal case, moving to have their names redacted. The Second Judicial Circuit Court denied their motion, reasoning that Marsy’s Law did not expressly provide a right to anonymity and that, even if the officers were assumed to be “victims,” their names alone did not constitute protected information under Marsy’s Law.On appeal, the Supreme Court of the State of South Dakota reversed and remanded. The Court held that law enforcement officers can qualify as “victims” under Marsy’s Law when a crime is committed against them. It further held that a victim’s name or initials are “information or records that could be used to locate or harass the victim or the victim’s family” and may be subject to redaction upon request. However, the Court clarified that Marsy’s Law does not grant a categorical right to redaction; rather, courts must balance victims’ rights with defendants’ and the public’s constitutional rights on a case-by-case basis. View "State v. Albaidhani" on Justia Law

The case concerns an inmate who, while incarcerated at a South Dakota prison, damaged prison property and engaged in a physical altercation with a correctional officer. The incident began when officers searched the inmate’s cell and confiscated his television for lacking required security stickers. In response, the inmate followed an officer to the day hall, broke a computer monitor with an electric kettle, and damaged a wall-mounted television. When officers intervened, the inmate was sprayed with pepper spray and then struck a correctional officer multiple times. The incident was captured by prison surveillance cameras, though the video contained a four-second gap due to technical issues.The Circuit Court of the First Judicial Circuit, Bon Homme County, presided over the trial. The inmate was charged with two counts of simple assault against a correctional officer and one count of intentional property damage. He was convicted by a jury of one count of simple assault and one count of intentional damage to property, but acquitted on the second assault count. The court denied his requests for a self-defense jury instruction, as well as his motions to dismiss based on double jeopardy and due process claims. The court also allowed the use of surveillance footage with the four-second skip, finding no evidence of misconduct or suppression by the State.On appeal to the Supreme Court of the State of South Dakota, the inmate raised issues regarding the propriety of the assault charge, the admission of the surveillance video, the refusal to give a self-defense instruction, the State’s alleged failure to preserve evidence, and double jeopardy. The Supreme Court affirmed the convictions, holding that the charging decision was not reviewable absent due process concerns, the video was properly admitted, there was insufficient evidence to warrant a self-defense instruction, no constitutional violation arose from the missing footage, and submitting alternative assault counts did not violate double jeopardy. View "State v. Warfield" on Justia Law

The defendant was convicted after a jury trial of aggravated eluding, reckless driving, driving under suspension, and failing to stop at a stop sign, all arising from an incident in Sioux Falls, South Dakota. Law enforcement responded to a call about a family dispute, with the caller reporting that the defendant was driving a red Toyota Camry. Officers observed the vehicle and identified the defendant as the driver, who then fled at high speed through residential neighborhoods. The defendant later testified that he was not involved, did not own or drive the Camry, and denied fleeing from police.The Circuit Court of the Second Judicial Circuit, Minnehaha County, presided over the trial. Prior to trial, the defendant moved to exclude statements related to the BOLO alert and the caller’s association of him with the Camry, arguing hearsay and character evidence grounds. The court denied these motions, reasoning that the BOLO and information about the vehicle were relevant to the officers’ actions and not unduly prejudicial. During trial, officers testified about the BOLO and caller’s statements, and defense counsel made a continuing objection referencing Crawford v. Washington. The jury returned guilty verdicts on all counts, and the defendant was sentenced with all terms suspended.The Supreme Court of the State of South Dakota reviewed the case. The defendant argued that admitting the caller’s statement violated his Sixth Amendment right to confrontation and constituted inadmissible hearsay. The court held that the defendant had not properly preserved the Confrontation Clause issue for appeal, as he failed to provide sufficient facts or request a determination about whether the caller’s statement was testimonial. Regarding hearsay, the court found that, even if error occurred, it was not prejudicial because the officers’ identification testimony and dash camera videos provided strong, independent evidence of the defendant’s identity. The Supreme Court affirmed the conviction. View "State v. Clifford" on Justia Law

A transgender woman petitioned the Sixth Judicial Circuit Court in Hughes County, South Dakota, to amend her birth certificate. She requested that the certificate reflect her legal name change, already recognized by Minnesota, and to change the sex designation from male to female, matching her gender identity. The Department of Health did not initially participate in the proceedings. The petitioner’s main argument on appeal concerned only the sex designation, asserting a right to have her birth certificate reflect her gender identity, referencing her legal documents as proof and citing constitutional guarantees of equal protection.The circuit court denied the petition. It interpreted the governing administrative regulation (ARSD 44:09:05:02) as permitting amendments only if the data was incorrect at the time of or immediately after birth. The court found that the certificate correctly reflected the facts at birth and was not meant to record changes occurring later in life. Regarding the equal protection claim, the court determined that neither a fundamental right nor a suspect classification was involved. It applied rational basis review, finding the rule rationally related to legitimate state interests, such as the accurate recording of newborn sex and the integrity of vital records.On appeal, the Supreme Court of the State of South Dakota reviewed both the regulatory interpretation and the equal protection claim de novo. The court affirmed the lower court’s decision, holding that the administrative rule unambiguously limits amendments to correcting errors existing at the time of birth and does not permit changes based solely on a subsequent change in gender identity. Furthermore, the court held that the regulation neither classifies on the basis of sex or transgender status nor targets a suspect class, and rational basis review is appropriate. The court concluded that the rule is rationally related to legitimate state objectives and does not violate equal protection. The judgment was affirmed. View "Amended Birth Certificate Of Nielsen" on Justia Law

Soloman Longchase was charged with multiple offenses, including aggravated assault (domestic), aggravated kidnapping, grand theft, interference with emergency communication, and false impersonation to deceive law enforcement, stemming from incidents on August 20, 2022. After the initial complaint and indictment, Longchase was held in the Hughes County Jail on unrelated charges. He was granted a medical furlough but failed to return, resulting in an escape charge and a period as a fugitive until his rearrest in December 2023. He later appeared in court for the Hyde County charges, was appointed counsel, and ultimately entered a plea agreement to plead guilty to grand theft and simple assault, with other charges dismissed.The Circuit Court of the Sixth Judicial Circuit, Hyde County, presided over the case. Longchase moved to dismiss the indictment, alleging a violation of his constitutional right to a speedy trial. The circuit court denied the motion after applying the Barker v. Wingo factors. At sentencing, the court ordered Longchase to reimburse the county for court-appointed attorney fees, finding he had the ability to work and pay after release from prison. Longchase objected, arguing the court was required to make specific findings about his ability to pay and that recoupment was unconstitutional given his current financial status.The Supreme Court of the State of South Dakota reviewed the case. It held that Longchase’s unconditional guilty plea waived his right to appeal the alleged speedy trial violation, as the right to a speedy trial is not a jurisdictional defect that survives a guilty plea. The court also held that the circuit court’s order requiring reimbursement of attorney fees did not violate Longchase’s constitutional rights to counsel or due process, as he was afforded counsel at all critical stages and had a meaningful opportunity to contest the recoupment order. The Supreme Court affirmed the circuit court’s rulings. View "State v. Longchase" on Justia Law

Nathan Parris was taken into protective custody by law enforcement after making suicidal statements and exhibiting concerning behavior. Officers searched him before transporting him to the hospital for a mental health evaluation and found a small, closed container in his pocket, which contained methamphetamine. Parris was charged with possession of a controlled substance and moved to suppress the drug evidence, arguing that the search of the container was impermissible.The Circuit Court of the Seventh Judicial Circuit in Pennington County, South Dakota, denied Parris's motion to suppress, finding that the officers had probable cause to take him into protective custody and that the search of the container was permissible. Parris was found guilty of possession of a controlled substance in a court trial based on stipulated facts.The Supreme Court of the State of South Dakota reviewed the case. The court held that the officers had probable cause to believe that Parris required emergency intervention due to his suicidal statements, emotional distress, and possession of a loaded handgun. The court also held that the search of the closed container was a reasonable administrative step to ensure the safety of Parris, the officers, and the facility, and was not conducted as part of a criminal investigation. Therefore, the search did not violate the Fourth Amendment.The Supreme Court affirmed the circuit court's decision, upholding Parris's conviction for possession of a controlled substance. View "State v. Parris" on Justia Law