Justia Constitutional Law Opinion Summaries

Defendant-Appellant Adam Olson entered into a plea agreement with the State, under the terms of which he pleaded guilty to one count of grand theft and one count of aggravated eluding of a law enforcement officer. Olson also admitted to being a habitual offender. In addition, Olson pleaded guilty to an additional count of grand theft, which the State charged him with, in a separate Information. Defendant later filed a motion to withdraw his guilty pleas. The circuit court denied his motion and sentenced him to fifteen years for the grand theft conviction and two years for the aggravated eluding of a law enforcement officer conviction. Defendant's sentence for aggravated eluding of a law enforcement officer was to run consecutive to his sentence for grand theft. The court also sentenced Defendant to serve ten years for the grand theft conviction that was charged in the separate Information. This sentence was to be served consecutive to his other sentences. Defendant appealed, raising: (1) whether the circuit court abused its discretion in denying his motion to withdraw his guilty pleas; (2) whether Defendant's sentences constituted cruel and unusual punishment under the Eighth Amendment. Upon review, the Supreme Court found no abuse of discretion nor a violation of Defendant's constitutional rights. Accordingly, the Court affirmed his conviction and sentence.

A jury found Defendant Leonard Alan Toohey guilty of first degree rape of a child. On appeal, he asserts that the child victim was not available for cross-examination as required under the Confrontation Clause, that the circuit court abused its discretion when it admitted evidence of other acts, and that there was insufficient evidence to support proof of penetration. Upon review of the trial court record, the Supreme Court found that "rational jurors could [have found] proof of penetration" beyond a reasonable doubt. Accordingly, the Court affirmed Defendant's conviction.

Dennis Most was convicted in a bench trial of four counts of sexual contact with a child. Most appealed, contending (1) the trial court erred in denying his motion to exclude prior acts evidence and his motion to offer the victim's prior allegation of sexual assault, and (2) there was insufficient evidence to sustain his convictions. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion when it admitted prior acts evidence; (2) the trial court did not abuse its discretion when it denied Most's motion to offer evidence of the victim's prior allegation of sexual assault; and (3) there was sufficient evidence to sustain Most's convictions.

John Graham, a Canadian citizen, was convicted of felony murder and sentenced to life imprisonment without parole. Graham appealed, raising a number of arguments, including the contention that because he was extradited from Canada on a federal premeditated murder charge, under the specialty doctrine of federal extradition law, the State lacked personal jurisdiction to prosecute him on the State felony murder charge. The Supreme Court affirmed, holding (1) because Canada consented to waive specialty with respect to the state charge at issue, the State had jurisdiction to prosecute Graham for felony murder; (2) the circuit court erred in admitting certain hearsay, but the error was harmless; (3) there was sufficient evidence to sustain a finding of guilt beyond a reasonable doubt; and (4) Graham's life sentence without parole was authorized by statute and was constitutional under the Eighth Amendment.

Kyle Steiner pleaded guilty to one count of sexual contact with a child and was sentenced to fifteen years in prison. Steiner subsequently filed an application for a writ of habeas corpus, claiming that his trial counsel was ineffective. Without conducting an evidentiary hearing, the circuit court dismissed the application. The Supreme Court reversed the judgment of the circuit court, holding that the circuit court was premature in dismissing Steiner's petition without conducting an evidentiary hearing on the merits, as Steiner alleged facts which, if proven to be true, would support a claim for relief, and Steiner's allegations were not unspecific, conclusory, or speculative.

A jury found Trent Danielson guilty of perjury. Danielson appealed, arguing that the evidence was insufficient to sustain the verdict, the trial court erred in denying his motion for a court-appointed private investigator, and the court erred in denying a motion in limine and admitting used transmission parts into evidence. The Supreme Court affirmed, holding (1) there was sufficient evidence to sustain the jury's guilty verdict, as a rational trier of fact could have found the essential elements of perjury beyond a reasonable doubt; and (2) the trial court did not abuse its discretion in denying Danielson's motion for appointment of a private investigator, motion in limine to exclude the transmission parts, and motion to dismiss for the destruction of evidence.

Appellant Ryan Rademaker was arrested for driving while under the influence of alcohol. Rademaker moved to suppress all evidence obtained from the stop of his vehicle, arguing that the stop violated his Fourth Amendment right to be free from unreasonable search and seizures. The trial court denied his motion and convicted Rademaker of driving under the influence. Rademaker appealed. The Supreme Court affirmed the trial court's ruling on the issue, holding that, based on the totality of the circumstances, the law enforcement officer had reasonable suspicion to stop Rademaker's car, and thus, the stop did not violate Rademaker's Fourth Amendment rights.

Eric Robert was under a sentence of death entered by a circuit court judge and let the time to file an appeal expire. Nevertheless, the Supreme Court in this case was statutorily obligated to review his sentence. The Court subsequently stayed Robert's execution and established a briefing schedule. Robert filed a motion to vacate those orders, arguing that the obligation to review his sentence did not grant the Court additional jurisdiction to stay his execution or to enter a briefing schedule. The Supreme Court denied the motion to vacate, holding that Robert's interpretation of S.D. Codified Laws 23A-27A-21, which included the argument that because Robert had not filed a notice of appeal the stay of proceedings contemplated by the statute was not available, was incorrect, as it would lead to an absurd result, flew in the face of the Court's authority, and was inconsistent with the constitutional analysis of the U.S. Supreme Court.

After a jury trial, Simon Torres was convicted of attempted murder and commission of a felony with a firearm. Torres appealed. The Supreme Court affirmed, holding that the trial court (1) did not abuse its discretion in denying Torres's motion in limine to exclude a cell phone video of the shooting and photographs of the victim's gunshot wounds, as Torres did not establish that the photographs were unfairly prejudicial or that the trial court incorrectly determined that the photographs' probative value outweighed this potential prejudice; and (2) did not violate Torres's due process rights during arraignment by failing to advise him that he would receive mandatory consecutive sentences if convicted of both attempted murder and commission of a felony with a firearm.

Without obtaining a search warrant, police attached a global positioning system (GPS) device to Elmer Zahn's vehicle. The GPS device enabled officers to track and record the speed, time, direction, and geographic location of Zahn's vehicle within five to ten feet for nearly a month. Police used the information they gathered to obtain a search warrant for two storage units that Zahn frequently visited. Officers subsequently recovered drug paraphernalia and drugs from one of the storage units. Before trial, the trial court denied Zahn's motion to suppress the evidence that the officers discovered during the execution of the search warrant. Zahn was subsequently convicted of several drug possession charges. The Supreme Court reversed, holding (1) the attachment and use of a GPS device to monitor an individual's activities over an extended period of time requires a search warrant; and (2) thus, the warrantless attachment and use of the GPS device to monitor Zahn's activities for nearly a month was unlawful, and the evidence obtained through the use of the GPS device should be suppressed.