Justia Constitutional Law Opinion Summaries

Over a period of two years, the City of Sioux Falls issued Daniel Daily four citations for a concrete extension to his driveway. Daily appealed each of the citations, but a hearing was held only on the final two citations received. Daily then initiated a declaratory judgment action against the City. The trial court ultimately concluded that the City's administrative appeals process, both as written and as applied, and the City's enforcement of its zoning ordinances violated Daily's constitutional rights to procedural due process and equal protection. The Supreme Court affirmed, holding (1) because the hearing examiner in this case did not hold the City to its burden of proof, the City's administrative appeals process deprived Daily of a protected property interest without due process of law; and (2) the hearing examiner's application of the rules of evidence deprived Daily of a fair hearing.

Defendant William Jensen was charged with fourth offense driving under the influence. He filed a motion to strike one of his three prior driving under the influence convictions, arguing that because the magistrate court relied on a statement of rights form to establish the voluntariness of his guilty plea during that prior hearing, that prior conviction was invalid for sentence enhancement purposes. The trial court denied Jensen's motion to strike, concluding that the statement of rights form was an adequate record of voluntariness. Jensen appealed. The Supreme Court affirmed, holding (1) because Jensen did not demonstrate prejudice, his challenge to his prior driving under the influence conviction was not proper for the Court's consideration; and (2) Jensen did not demonstrate that the magistrate court's failure to personally canvass him to establish the voluntariness of his plea violated his due process rights.

Defendant Ivan Good Plume was found guilty of aggravated assault and of being a habitual offender and was sentenced to eighteen years in prison. On appeal, defendant asserted (1) that the sentencing judge, in referring to a pattern of drunken violence by Good Plume as "going native," evinced his personal bias against defendant and used race as a sentencing factor, thus violating defendant's federal and state due process rights; and (2) the judge abused his discretion in admitting into evidence a letter defendant wrote without considering the requirements of S.D. R. Evid. 404(b) before admitting it. The Supreme Court affirmed, holding (1) defendant did not meet his burden of making a specific and substantial showing that a racial or personal bias was used as an aggravating factor in his sentence, and (2) the letter was admitted not to prove defendant engaged in other wrongs, crimes, or acts but as res gestae evidence necessary to prove intent.

The South Dakota Department of Transportation (DOT) obtained title to land once owned by Defendants Philip Clark, P&J Enterprises, LLC and Hansen Manufacturing Corporation by eminent domain. The jury determined the amount of compensation to award for the taking. The trial court subsequently awarded prejudgment interest and attorneyâs fees to Defendants. The DOT challenged the award of attorneyâs fees. The Supreme Court found that the plain language of the applicable state law allows for an award of prejudgment interest and attorneyâs fees in connection with eminent domain takings. Accordingly, the Court affirmed the trial courtâs decision.

Petitioner James Lawrence appealed the circuit courtâs denial of his petition for habeas corpus, arguing that there was insufficient evidence to support his conviction and sentence for âtheft by deception.â In 1996, Petitioner approached the victim four times over the course of several months, offering to perform home repairs that he said would be reimbursed under a federal government program. By the end, Petitioner had received over $5,000 for his âwork.â Petitioner furnished invoices he claimed would be reimbursed and an âofficialâ called the victim to arrange to inspect the work Petitioner had done. When the inspector never showed, the victim called the local branch of the government agency to follow up, and learned that the alleged reimbursement had ended several years earlier. In 2003, a jury found Petitioner guilty of theft by deception and sentenced him to twenty-five yearsâ imprisonment at the state penitentiary. The appellate court affirmed his conviction. In 2006, Petitioner sought the writ of habeas corpus, alleging among other things, that his constitutional rights had been violated because he was convicted on insufficient evidence. The circuit court denied his motion, and Petitioner brought his appeal to the Supreme Court. The Supreme Court concluded that there was ample evidence from which the jury could draw its conclusion. The Court affirmed the lower courtsâ decisions to dismiss Petitionerâs appeals.