Justia Constitutional Law Opinion Summaries

Christopher Fisher was convicted of manslaughter following the death of a fifteen-month-old child. Fisher appealed, contending that the trial court erred in (1) failing to suppress incriminating statements Fisher made during an interview with law enforcement, (2) admitting a portion of a videotaped interrogation where Fisher was depicted shaking a doll with the image of the doll redacted; and (3) finding that one of the state's expert witnesses was qualified to testify about abusive head trauma. The Supreme Court affirmed, holding (1) Fisher's confession during his interrogation was voluntary, and the trial court did not err in denying his motion to suppress; (2) the trial court did not err in admitting the redacted video of Fisher shaking the doll as the evidence was insufficient to mislead the jury or unfairly prejudice Fisher; and (3) the trial court did not abuse its discretion in allowing the expert witness to testify because the evidence in the record supported the trial court's conclusion that the witness had sufficient knowledge, training or education to offer her opinion on the child's cause of death.

Lacy March sought a protection order against Roger Thursby, which the circuit court granted. The testimony elicited at trial concerned stalking. Thursby appealed, alleging, among other things, that the findings of fact were insufficient to support the order as signed. The Supreme Court reversed due to insufficiency of the findings of fact, holding the circuit court failed to insure that the findings of fact and conclusions of law were clearly entered. Specifically, the Court found that although the circuit court indicated that it believed March's version of the events, the written finding did not correspond with the oral testimony of March, and the court did not indicate how the evidence met the statutory elements of stalking.

Lucas Waugh was charged with attempted rape of a woman and the rape of a minor. The incidents occurred one after the other within walking distance of each other. The circuit court joined the cases for trial, and a jury found Waugh guilty of both offenses. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in joining the charges for trial because (i) the two incidents in this case were closely related in time, location, and manner of execution, and (ii) there was no undue prejudice because the evidence of each incident could have been admitted in the trial of the other; and (2) the evidence was sufficient for a reasonable trier of fact to have found Waugh guilty of both offenses.

Defendant Christopher Jones was convicted of raping a twenty-three-year-old woman who testified that she was too intoxicated to have consented. The defendant appealed, asserting that although S.D. Codified Laws 22-22-1(4) does not explicitly include a knowledge element, the circuit court erred when it failed to instruct the jury that the State must prove that the defendant knew that the woman's intoxicated condition made her unable to consent. The Supreme Court reversed, holding that the Legislature intended that a rape conviction under section 22-22-1(4) requires proof that the defendant knew or reasonably should have known that the victim's intoxicated condition rendered her incapable of consenting. Remanded for a new trial.

Appellant Mil Hirning pleaded guilty to unauthorized possession of a controlled substance and admitted to being a habitual offender. Hirning made the plea after Hirning's trial counsel withdrew from representing him and Hirning proceeded pro se. On appeal, Hirning argued that his waiver of counsel was not voluntary, knowing, and intelligent. The Supreme Court reversed Hirning's convictions and sentence, (1) finding that Hirning was not warned of the dangers of self-representation, and (2) holding that the record did not indicate circumstances from which the Court could find Hirning was aware of the danger and made a voluntary, knowing, and intelligent waiver. Remanded.

At issue in this appeal was a zoning ordinance adopted by the City of Sioux Falls requiring that an on-sale alcoholic beverage business seeking to place video lottery machines in the establishment must meet certain location requirements and apply for a conditional use permit. Plaintiff Rick Law, who conditionally held a liquor license, brought a declaratory action against the City to determine the constitutionality of the ordinance. The South Dakota Lottery intervened in the action. The circuit court ruled that the City exceeded its authority when it enacted the ordinance, concluding that South Dakota's constitutional and statutory scheme indicated that the State intended to fully occupy the field of video lottery to the exclusion of municipal regulation. The Supreme Court affirmed, holding that (1) municipalities do not have the freedom or power to regulate video lottery as the South Dakota Constitution specifically reserves that right to the State and (2) existing legislation does not give municipalities power to license video lottery establishments or otherwise control the location of such establishments.

Petitioner Dale Guthmiller was convicted of criminal pedophilia and sentenced to life in prison. Petitioner subsequently petitioned the circuit court for a writ of habeas corpus, alleging, among other things, that the trial judge made improper comments during the trial, violating Petitioner's constitutional right to a fair trial. The habeas court granted Petitioner's writ on reconsideration, (1) concluding that the trial judge's comments created a structural error negating Petitioner's requirement to establish prejudice, and (2) retracting its earlier ruling that trial counsel's failure to object was not prejudicial. The Supreme Court reversed, holding (1) the trial judge's comments did not constitute a structural error, and (2) despite defense counsel's failure to object to the judge's improper remarks, Petitioner did not meet his burden of showing that the jury's verdict would reasonably likely have been different absent trial counsel's errors.

The underlying action in this case involved a dispute among a family-owned corporation's shareholders concerning the management and control of the business. The two factions asked circuit court judge John Delaney to determine the corporation's value. Before trial, Delaney entered an order that (1) imposed a gag order on the parties and (2) closed the trial and court records. Several media entities (the Media) petitioned for a writ of mandamus or prohibition, asserting that Delaney's gag order unlawfully interfered with Media's First Amendment and common law rights. The Supreme Court granted Media's request for a permanent writ of prohibition, holding (1) although the underlying trial was complete, Media's claims could be considered under an exception to the mootness doctrine because the issue presented was capable of repetition yet evading review; (2) the First Amendment affords the media and public a qualified right of access to civil trials in the state; (3) Delaney abused his discretion in closing the trial proceedings from the media and public because the procedure and reasoning he used was flawed; and (4) Delaney did not have statutory or legal authority to issue the gag order under the facts and circumstances of this case.

Plaintiffs, a group of children who attended public schools in several South Dakota school districts and their parents and natural guardians, asked for a declaratory ruling that the state's present system of funding education was unconstitutional because it did not provide all children with an adequate and quality education. At issue was (1) S.D. Const. art. 8, 1 & 15, which requires the Legislature to establish and maintain a general and uniform system of public schools and provide funding to secure a thorough and efficient system of common schools throughout the state and (2) whether the legislative scheme for funding education met the constitutional requirements. The circuit court issued a judgment in favor of defendants, holding that the resources, curriculum, and facilities currently provided to students were constitutionally sufficient. The Supreme Court affirmed, holding that the current educational funding system failed to correlate with adequate student achievement to the point of declaring the system unconstitutional.

In 2007, Davison County adopted a county-wide plan to reassess agricultural structures. The County reassessed agricultural structures in four of its twelve townships that year. Donald and Gene Stehly, who owned agricultural structures in the four reassessed townships, initiated a declaratory judgment action, alleging that the plan to reassess four townships each year created an unconstitutional lack of uniform taxation within the county. The trial court concluded that the Stehlys' claim failed because they did not establish lack of uniformity within a single taxing district as required by the South Dakota Constitution. The Supreme Court affirmed, holding (1) townships are taxing districts under the Constitution, and (2) a reassessment plan that creates a temporary lack of uniform taxation among townships within a county is constitutional.