Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of burglary and two counts of simple assault arising from a home invasion, holding that Defendant was not entitled to relief on his allegations of error.After a jury trial, Defendant was convicted of burglary and simple assault. Defendant was tried on a part two habitual offender information alleging two prior felon convictions. The jury found Defendant to be a habitual offender. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Defendant's motion to suppress the show-up identification; (2) did not err in denying Defendant's motion for a mistrial; and (3) did not err in denying Defendant's motion for judgment of acquittal in the habitual offender trial. View "State v. Red Cloud" on Justia Law

The Supreme Court affirmed the magistrate court's decision granting Defendant's motion to suppress, holding that the magistrate court did not err in determining that the community caretaker exception to the Fourth Amendment did not apply.After Sioux Falls dispatch received a call from a six-year-old boy saying that "daddy was being mean to mom" and that his dad was leaving to go to his car an officer followed the dad (Defendant) in his automobile. The officer initiated a traffic stop and, after further investigation, placed Defendant under arrest for driving under the influence and driving with a suspended license. Defendant filed a motion to suppress, arguing that the officer stopped his car without probable cause or a reasonable and articulable suspicion. The magistrate court granted the motion to suppress. The Supreme Court affirmed, holding that the officer's actions were beyond the scope of a community caretaker, and therefore, Defendant's motion to suppress was properly granted. View "State v. Grassrope" on Justia Law

The Supreme Court affirmed the judgment of the habeas court dismissing Defendant's application for habeas corpus, holding that the court did not err.A jury convicted Defendant of fourteen sex offenses. On appeal, Defendant argued that his due process right to jury unanimity was denied and that the prosecutor's remarks during opening statement denied him a fair trial. The Supreme Court affirmed. Defendant later filed an application for writ of habeas corpus alleging ineffective assistance of counsel based on the errors he alleged on appeal. The habeas court dismissed the application. The Supreme Court affirmed, holding (1) Defendant was precluded from demonstrating prejudice for Strickland purposes in a subsequent habeas corpus proceeding; and (2) the habeas court properly dismissed Defendant's amended application for a writ of habeas corpus on summary judgment. View "Neels v. Dooley" on Justia Law

The Supreme Court affirmed the circuit court's dismissal of this election contest and its determination that Constitutional Amendment A was submitted to the voters at the November 3, 2020 election in violation of the single subject requirement in S.D. Const. art. XXIII, 1, holding that the circuit court did not err.At the election at issue, South Dakota voters approved Amendment A, "An amendment to the South Dakota Constitution to legalize, regulate, and tax marijuana; and to require the Legislature to pass laws regarding hemp as well as laws ensuring access to marijuana for medical use." Plaintiffs filed a statutory election contest and a separate declaratory judgment action claiming Amendment A was unconstitutional. The circuit court dismissed the election contest, concluding it was not an appropriate proceeding to challenge the amendment, but concluded in the declaratory judgment action that Amendment A violated Articles XXIII, 1 and 2. The Supreme Court affirmed, holding (1) Plaintiffs identified no irregularity in the election process; and (2) the submission of Amendment A to the voters plainly and palpably violated Article XXIII, 1. View "Thom v. Barnett" on Justia Law

The Supreme Court affirmed the decision of the Department of Public Safety to disqualify Appellant's commercial driver's license (CDL) for one year after he pled guilty to driving under the influence (DUI) and received a suspended imposition of sentence, holding that the Department properly disqualified Appellant's CDL.On appeal, Appellant argued that the Department violated the doctrine of separation of powers under the state constitution by unconstitutionally infringing upon the judiciary's sentencing authority and that the Department no longer had the statutory authority to disqualify Appellant's CDL once his case was dismissed and discharged. The Supreme Court affirmed, holding (1) Appellant failed to show that South Dakota's CDL disqualification statutes violate the separation of powers doctrine in article II of the state constitution; and (2) the Department properly considered Appellant's 2016 DUI conviction for the purpose of CDL disqualification under S.D. Codified Laws 32-12A-32. View "Jans v. Department of Public Safety" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court denying both parties' summary judgment motions as to Plaintiff's 42 U.S.C. 1983 claims, holding that the circuit court erred in denying summary judgment in favor of the City of Sioux Falls.Plaintiff brought this action against certain officers of the Sioux Falls Police Department and the City of Sioux Falls. The police officers and the City filed a motion for summary judgment. The circuit court (1) concluded that the officers were not entitled to qualified immunity; (2) denied summary judgment on Plaintiff's claim against the City due to material issues of fact. The Supreme Court held that the circuit court (1) erred in denying summary judgment on Plaintiff's claim that the officers' warrantless entry into her apartment violated her constitutional right to be free from unreasonable searches and seizures; (2) erred in denying the City's motion for summary judgment; and (3) properly concluded that material issues of fact were in dispute on the question of whether the officers used excessive force such that Defendants were not entitled to qualified immunity as a matter of law on this section 1983 claim. View "Boggs v. Pearson" on Justia Law

The Supreme Court affirmed Defendant's conviction of driving a vehicle with alcohol in the blood in violation of S.D. Codified Laws 32-23-1(1), holding that the magistrate court's finding that Defendant provided valid, voluntary consent to the blood draw was not clearly erroneous.After law enforcement officers arrested Defendant for driving under the influence one of the officers asked Defendant if he would consent to a blood draw. Defendant twice answered, "okay," and his blood was drawn without a warrant. Defendant filed a motion to suppress, arguing that the blood draw was taken without a warrant or his valid consent. The magistrate court denied the motion. The circuit court affirmed. The Supreme Court affirmed, holding that the circuit court (1) applied the correct standard of review to the magistrate court's decision; and (2) did not err in affirming the magistrate court's decision that Defendant provided valid, voluntary consent to the blood draw. View "State v. Slepikas" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree rape and simple assault, holding that the circuit court did not err when it denied Defendant's motion for a judgment of acquittal on the second-degree rape charge.Specifically, the Supreme Court held (1) there was sufficient evidence to sustain Defendant's conviction for second-degree rape because there was sufficient evidence of "force" as required under S.D. Codified Laws 22-22-1(2); (2) the circuit court did not commit plain error by allowing certain testimony; and (3) the representation provided by Defendant's trial counsel was not constitutionally deficient. View "State v. Townsend" on Justia Law

The Supreme Court affirmed Defendant's convictions for vehicular homicide and driving under the influence, holding that the evidence was sufficient to support the convictions and that the circuit court's error in denying Defendant's motion to suppress was harmless.On appeal, Defendant argued that the circuit court erred when it denied her motion to suppress a statement that she made to law enforcement officers at the hospital and when it denied her motion for a judgment of acquittal. The Supreme Court affirmed, holding (1) the circuit court erred by denying Defendant's suppression motion, but the error was harmless given the overwhelming evidence against her; and (2) the evidence was sufficient to sustain Defendant's convictions. View "State v. Angle" on Justia Law

The Supreme Court affirmed Defendant's sentence entered after he pled nolo contendere to three counts of possession of child pornography pursuant to a plea agreement, holding that the sentence did not violate the Eighth Amendment or constitute an abuse of discretion.The circuit court sentenced Defendant to ten years' incarceration, with six years suspended on each count and credit for time served. The court ordered counts one and two to be served consecutively with count three to run concurrently. The Supreme Court affirmed, holding (1) Defendant's sentence did not violate the Eighth Amendment's prohibition against cruel and unusual punishment; and (2) the circuit court did not abuse its discretion in sentencing Defendant. View "State v. Miles" on Justia Law