Justia Constitutional Law Opinion Summaries

Appellant appealed his conviction of five counts of possessing child pornography. Appellant argued (1) there was insufficient evidence to prove that he knowingly possessed child pornography; (2) S.D. Codified Laws 22-24A-3, the statute defining possession of child pornography, is unconstitutionally vague; and (3) he was convicted multiple times for a single act or course of conduct in violation of double jeopardy protections. The Supreme Court affirmed, holding (1) there was sufficient evidence for the jury to find that Appellant knowingly possessed the five images of child pornography for which he was charged; (2) there was no plain error for the court to notice with regard to the constitutionality of section 22-24A-3; and (3) there was no plain error for the court to notice with regard to double jeopardy. View "State v. Linson" on Justia Law

A law enforcement officer need not have independent authority to make an arrest under S.D. Codified Laws 23A-3-2 before taking a person placed under a citizen’s arrest into custody and performing a search incident to that arrest. Defendant in this case was validly placed under citizen’s arrest for theft by an asset protection associate at Walmart. The associate contacted law enforcement, who took Defendant into custody and searched her purse. Law enforcement found a pipe with methamphetamine residue. The circuit court granted Defendant's motion to suppress all evidence obtained from the search. The Supreme Court reversed based on South Dakota’s statutes concerning a citizen’s arrest and court precedent, holding that Defendant was validly placed under citizen’s arrest, and the responding law enforcement officer who took her into custody properly performed a search incident to that arrest. View "State v. Lee" on Justia Law

Defendant appealed his convictions, entered after a jury trial, of three counts of first-degree rape and one count of sexual contact with a child under sixteen years of age. The child was Defendant’s four-year-old daughter, who had autism. The Supreme Court affirmed, holding that the circuit court (1) did not abuse its discretion by finding the child, who was six years old at the time of trial, competent to testify despite her young age and developmental delays; (2) did not err in denying Defendant’s motion to have the child declared unavailable as a witness for the purposes of cross-examination because of her lack of memory; (3) did not err by denying Defendant’s pretrial motion to suppress his statements to law enforcement; and (4) did not abuse its discretion by giving Instruction 11 to the jury. View "State v. Spaniol" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and kidnapping. Defendant received concurrent, mandatory life sentences for the convictions. Defendant was fourteen years old when he committed the offenses. After the United States Supreme Court issued its decision in Miller v. Alabama, Defendant filed a motion in circuit court to correct an illegal sentence. The circuit court granted the motion. Following a resentencing hearing, the sentencing court resentenced Defendant to concurrent, 200-year sentences for first-degree murder and kidnapping. The Supreme Court affirmed, holding (1) Defendant failed to establish that his sentence is cruel and unusual in violation of the Eighth Amendment; and (2) the sentencing court did not abuse its discretion when it imposed concurrent, 200-year sentences. View "State v. Jensen" on Justia Law

After a court trial, Defendant was found guilty of driving with a .08 percent blood alcohol content. Defendant also pleaded guilty to a part II information alleging that this was his second driving under the influence offense. Defendant appealed the denial of his motion to suppress statements that he made to law enforcement that he had been drinking and driving, asserting that the statements were made in violation of his Miranda rights. The Supreme Court affirmed, holding that the totality of the circumstances surrounding the encounter between Defendant and the law enforcement officer did not amount to a custodial interrogation, and therefore, the circuit court did not err by denying Defendant’s motion to suppress any incriminating statements made during the encounter. View "State v. Hopkins" on Justia Law

Twin brothers Ryan Alan Krause and Brian Michael Krause pleaded guilty to separate complaints alleging grand theft and four counts of unlawfully using a computer. The circuit court sentenced each of the Krauses to four years imprisonment for grand theft and two years imprisonment for each count of unlawfully using a computer system, and ordered all sentences to run consecutively. The Supreme Court affirmed, holding (1) the Krauses’ consecutive sentences for unlawfully using a computer system do not violate the Eighth Amendment’s prohibition against cruel and unusual punishment; and (2) the circuit court did not err by imposing sentences of imprisonment instead of probation for the unlawful-use-of-computer-system convictions. View "State v. Krause" on Justia Law

Defendant was convicted of driving under the influence. Defendant appealed, arguing that the trial court erred in denying his motion to suppress evidence resulting from a traffic stop, including the results of a blood test, arguing that the arresting officer lacked reasonable suspicion to conclude that Defendant had committed a crime in order to justify the traffic stop. The Supreme Court reversed, holding that the circuit court erred in denying Defendant’s motion to suppress because the arresting officer did not have a reasonable suspicion of criminal activity, and any evidence resulting from the stop was the product of an illegal search. View "State v. Stanage" on Justia Law

Defendant was convicted of first-degree murder and received a mandatory sentence of life in prison. Defendant was fourteen years old when he committed the offense. After the United States Supreme Court issued Miller v. Alabama, which barred mandatory life sentences against juvenile homicide offenders, Defendant filed a motion to have his sentence correct. After a hearing, the sentencing court resentenced Defendant to ninety-two years in prison. The Supreme Court affirmed, holding (1) a ninety-two-year sentence is not categorically unconstitutional for a fourteen-year-old child; (2) because Defendant had the opportunity for release at age sixty, his sentence was not the legal equivalent of a life sentence without parole; (3) the sentencing court properly considered the mitigating qualities of youth set forth in Miller; (4) Defendant’s sentence was not grossly disproportionate to the gravity of the offense; and (5) the sentencing court did not commit prejudicial error when it permitted an oral victim-impact statement by an individual outside the statutory definition of a victim. View "State v. Charles" on Justia Law

Sueellan Kline and her boyfriend, Douglas Strong, a parolee, lived together in a motel room. Parole agent Connie Johnson went to the motel room to obtain a urine sample from Strong. When Strong’s urine field-tested positive to methamphetamine Johnson removed Strong from the room and detained him in the hallway. Johnson then reentered the room and asked Kline if there were drugs or drug paraphernalia in the room. In response, Kline removed a methamphetamine pipe from her purse and handed it to Johnson. The pipe was used to obtain a search warrant for Kline’s urine, which tested positive for methamphetamine and amphetamine. Kline filed a motion to suppress the evidence, arguing that it was obtained as the result of an illegal search. The circuit court denied the motion. Kline was subsequently convicted of ingestion of a controlled substance. The Supreme Court affirmed, holding that Johnson lawfully reentered the residence and that Kline voluntarily consented to production of the methamphetamine pipe, and therefore, the evidence was not obtained in violation of the Fourth Amendment. View "State v. Kline" on Justia Law

JB Enterprises (JBE) owned property located on a corner lot abutting Cliff Avenue and 63rd Street in Sioux Falls. Prior to initiating a public improvement reconstructing the interchange at Interstate 90 and Cliff Avenue, the State instituted a quick-take condemnation action against JBE, contesting JBE’s “control of access” to its property. The State ultimately changed the public improvement and left intact JBE’s curb cut along Cliff Avenue. After the State closed the intersection of 63rd Street and Cliff Avenue, JBE requested a jury trial on damages, alleging that the State owned JBE’s right to “control of access” to its property. The circuit court granted summary judgment in favor of the State, concluding that the State’s public improvement did not result in a compensable taking because the State did not physically take any of JBE’s property and did not eliminate JBE’s direct access to Cliff Avenue. The Supreme Court reversed, holding that because the State acquired the right to deprive JBE of access to Cliff Avenue, JBE must be compensated under the assumption that the State will do so. Remanded for a trial on damages. View "State v. JB Enterprises, Inc." on Justia Law