Justia Constitutional Law Opinion Summaries

After a jury trial, Appellant was convicted of driving under the influence of alcohol (DUI) and driving while having a 0.08 percent or more by weight of alcohol in the blood. Appellant appealed in part the trial court's admission of certain testimony regarding the Horizontal Gaze Nystagmus (HGN) test, which the arresting officer conducted during the stop of Appellant's vehicle. The Supreme Court affirmed the convictions, holding (1) even if the trial court erred in allowing the arresting officer to testify about the reliability of HGN testing and the correlation between an individual's performance on an HGN test and the individual's blood alcohol content, the error was harmless; and (2) the trial court did not err in denying Appellant's motion for a judgment of acquittal because there was sufficient evidence from which the jury could have convicted Appellant of DUI beyond a reasonable doubt. View "State v. Yuel" on Justia Law

Plaintiff, the former Jerauld County State's Attorney, brought a quo warranto action seeking to oust Defendant, the newly-elected State's Attorney, claiming Defendant did not qualify for and was not entitled to the office of Jerauld County State's Attorney. The circuit court denied relief, concluding that Defendant was the rightful holder of the office and was legally entitled to it. The Supreme Court affirmed, holding that because there was no evidence that Defendant usurped, intruded into, unlawfully held, or exercised the public office of Jerauld County State's Attorney, the circuit court correctly denied quo warranto relief. View "Bridgman v. Koch" on Justia Law

Defendant was charged with driving under the influence of alcohol (DUI). A part two information alleged that Defendant had two previous DUI convictions within the last ten years, including one in 2011. Defendant filed a motion to strike the 2011 conviction from the part two information, claiming that his guilty plea was invalid because he was not fully advised that he would waive his right to a jury trial, right to confrontation, and right against self-incrimination. The circuit court agreed with Defendant and ordered that the 2011 conviction be stricken from the part two information. The Supreme Court reversed, holding that the circuit court erred when it struck Defendant's 2011 conviction from the part two information, as the record affirmatively showed that Defendant was fully advised of his rights under Boykin v. Alabama during his 2011 conviction and intelligently and voluntarily waived those rights. View "State v. Smith" on Justia Law

Defendant was charged with possession of cocaine, possession of marijuana, and ingestion of marijuana. Defendant moved to suppress the evidence as the fruit of an illegal search of his hotel room. The trial court granted the motion with respect to the drugs seized during the initial illegal search but denied the motion with respect to evidence gathered during a subsequent call to the hotel. After a trial, Defendant was convicted as charged. The Supreme Court affirmed, holding the trial court did not err in denying in part Defendant's motion to suppress evidence, as the second call to police constituted an independent source of evidence against Defendant and that the evidence obtained thereby bore no causal connection to the evidence illegally seized in Defendant's hotel room. View "State v. Heney" on Justia Law

After a jury trial, Defendant was convicted of first-degree kidnapping, second-degree rape, and aggravated assault. The Supreme Court affirmed Defendant's convictions. Defendant subsequently filed an amended application for writ of habeas corpus, alleging that he was denied effective assistance of counsel, a fair trial, and due process of law. The habeas court denied the writ. The Supreme Court affirmed, holding (1) the habeas court correctly determined that Defendant failed to demonstrate ineffective assistance of counsel; (2) Defendant's due process claim regarding cross-examination of the victim concerning her sexual activity before the rape and her post-rape drug charge were res judicata; and (3) the habeas court correctly determined that Defendant's remaining due process argument lacked evidentiary support. View "Fast Horse v. Weber" on Justia Law

Defendant and his stepson were jointly charged with thirteen felonies. Prior to trial, Defendant unsuccessfully moved to sever charges and for relief from prejudicial joinder. At trial, Defendant filed a motion for judgment of acquittal on all charges stemming from two of the burglaries, which the trial court also denied. Defendant was subsequently convicted on nine of the thirteen felonies. The Supreme Court affirmed, holding that the trial court did not err in (1) denying Defendant's motion for judgment of acquittal because the evidence was sufficient to support Defendant's convictions; and (2) denying Defendant's motion to sever charges and for relief from prejudicial joinder because the charges were properly joined and Defendant failed to show the denial of his motion to sever charges resulted in clear prejudice to his substantial rights. View "State v. Dowty" on Justia Law

The South Dakota Department of Labor and Regulation, Unemployment Insurance Division disqualified Plaintiff from unemployment insurance benefits based on Plaintiff's alleged failure, without good cause, to accept work she was capable of performing. After Plaintiff missed a telephonic hearing on her appeal, an ALJ entered an order of dismissal and denied Plaintiff's request to reopen for failure to show good cause. The circuit court affirmed, concluding that the Department did not err in refusing to reopen Plaintiff's claim. The Supreme Court affirmed dismissal, holding that Plaintiff did not provide evidence of untimely receipt of her notice of the hearing to carry her burden to show good cause, and therefore, Plaintiff received sufficient due process. View "Eiler v. Dep't of Labor & Regulation" on Justia Law

In the first appeal of this medical malpractice suit, the Supreme Court reversed and remanded a judgment for defendant Dr. Linda Peterson, holding that the trial court abused its discretion when it misconstrued the rules of evidence on the relevancy and admissibility of plaintiff Lita St. John's proffered evidence. On remand, defendant asked for reconsideration of the evidentiary rulings and reinstatement of the judgment. Concluding that the Supreme Court's opinion still left open the question whether the evidence was admissible, and ruling that it was not, the trial court declined to grant plaintiff a new trial and reinstated the judgment for defendant. Upon re-review, the Supreme Court reversed and remanded. "Many issues addressed by motions in limine, including evidentiary issues, are frequently reexamined during trial and the trial court may change rulings based on the actual evidence at trial. Thus, it was an error for the trial court in this case to reinstate a judgment based on reconsidering and ruling on a motion in limine outside of the context of a trial. We reverse the trial court's decision and remand for a new trial." View "St. John v. Peterson" on Justia Law

Hutterville Colony, a nonprofit religious corporation, had two opposing factions. Both factions sought exclusive power over Hutterville. Their schism led to two lawsuits, including one faction's suit seeking judicial dissolution of Hutterville. Eventually, the Supreme Court ordered dismissal of the suit, concluding that the circuit court lacked subject matter jurisdiction to order judicial dissolution of Hutterville. This appeal concerned the circuit court's actions following the Court's decision. The Supreme Court affirmed, holding (1) the circuit court did not err when it continued to exercise jurisdiction over Hutterville and its property following remittitur; (2) the circuit court had the authority and duty to wind up the receivership and discharge the receiver; (3) the circuit court did not abuse its discretion in ordering payment of the receiver's fees and expenses from receivership funds and allowing the receiver to use receivership funds to pay the expenses of third parties; (4) the circuit court did err in releasing the receiver from liability, as the receiver's appointment and receivership were valid under state law; and (5) the circuit court did not err in ordering the receiver to return receivership funds to the corporation. View "Wipf v. Hutterville Hutterian Brethren" on Justia Law

After a jury trial, Defendant was convicted of manslaughter in the first degree. The Supreme Court affirmed, holding that the trial court (1) did not abuse its discretion in denying Defendant's motion to suppress and in admitting a video of Defendant's first interrogation, as Defendant made a knowing, voluntary, and intelligent waiver of her Miranda rights in the first interrogation; (2) did not err in refusing to instruct the jury on the lesser offense of manslaughter in the second degree; and (3) did not err in denying a jury instruction on burglary and allowing Defendant's counsel to appropriately argue the elements of justifiable homicide. View "State v. Waloke" on Justia Law