Justia Constitutional Law Opinion Summaries

The Supreme Court reversed the orders of the circuit court sustaining Defendants' motions to suppress evidence seized by law enforcement, pursuant to a search warrant, at the apartment where Defendants resided, holding that probable cause existed for the issuance of the search warrant.Defendants - Carrie Lynn Ostby and Dana Olmsted - were indicted on drug-related charges. The circuit court granted Defendants' motions to suppress, determining that probable cause did not exist for the warrant to search Defendants' apartment and that the exigent circumstances exception to the warrant requirement was inapplicable. The Supreme Court reversed, holding (1) the affidavit in support of the search warrant established probable cause to search the apartment where Defendants resided; and (2) therefore, it was unnecessary to consider whether the good-faith exception applied to the exclusionary rule. View "State v. Ostby" on Justia Law

The Supreme Court issued an advisory opinion requested by the Governor of the State of South Dakota questioning whether the South Dakota Constitution or any state law prohibits a current state legislator from being eligible to receive funds from coronavirus relief fund (CRF) Grant Programs. The Supreme Court concluded that a solemn occasion existed and that it would answer the question posed. The Court then answered that S.D. Const. Art. III, 12 precludes a current state legislator from contracting directly or indirectly with the State to receive funds from CRF Grant Programs. View "In re Interpretation Of South Dakota Constitution and State Laws Regarding Eligibility For CRF Grant Programs" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree burglary and grand theft, holding that the circuit court did not err when it denied Defendant's motion to suppress and when in denied Defendant's motion for expert fingerprint testing.Defendant filed a motion to suppress gun evidence that was returned to the owner before trial, arguing that the State would be unable to establish a proper chain of custody. The circuit court denied the motion to suppress. The Supreme Court affirmed, holding (1) although the law enforcement officers and the prosecutor did not comply with statutory standards before releasing the evidence to its owner, the circuit court did not err in denying the motion to suppress because the guns did not possess apparent exculpatory value; and (2) even if the circuit court abused its discretion by denying Defendant's request for fingerprint testing, there was no prejudice. View "State v. Zephier" on Justia Law

The Supreme Court affirmed the judgment of the circuit court affirming Defendant's magistrate court conviction for operating an onsite wastewater system without a permit, holding that the City's ordinance as applied to Defendant was not an ex post facto law.Defendant was convicted for failure to obtain a permit in violation of Rapid City Municipal Code (RCMC) 13.20.800. On appeal, Defendant argued that RCMC 13.20.800 violated the ex post facto clauses of the state and federal constitutions, was preempted by state administrative rules, and exceeded Rapid City's authority since Defendant lived outside of the city's limits. The circuit court affirmed the conviction. The Supreme Court affirmed, holding (1) the City's sewerage permit ordinance was not an ex post facto law because it punished Defendant for conduct occurring after the ordinance was enacted; (2) RCMC 13.20.800 does not conflict with state administrative regulations; and (3) there was no merit to Defendant's argument that the City lacked authority to enforce the ordinance beyond its municipal boundaries. View "City Of Rapid City v. Schaub" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree rape and sexual contact involving a second victim, holding that Defendant's allegations of error were unavailing.Specifically, the Supreme Court held (1) the circuit court did not abuse its discretion by allowing evidence of Defendant's two prior alleged sexual assaults; (2) the admission of other act evidence did not violate Defendant's constitutional rights under the Double Jeopardy and Due Process Clauses; (3) the circuit court did not abuse its discretion when it denied Defendant's motion for a mistrial; (4) there was sufficient evidence to support the conviction; (5) the circuit court erred in admitting forensic laboratory reports by affidavit without affording Defendant the opportunity to cross-examine the analysts who conducted the testing and authored the reports, but the error was not prejudicial; and (6) Defendant's sentence did not violate the Eighth Amendment. View "State v. Taylor" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's motion to suppress evidence obtained as a result of his encounter with police, holding that the circuit court properly denied the motion to suppress.Defendant was charged with possession of controlled substances, a loaded firearm while intoxicated, marijuana, and drug paraphernalia. Defendant filed a motion to suppress evidence obtained from a stop of his person on the basis that it violated the Fourth Amendment. The circuit court denied the motion, concluding that the search was done in accordance with Terry v. Ohio, 392 U.S. 1 (1968) and its progeny. The Supreme Court affirmed, holding (1) under the totality of the circumstances, the officers had reasonable suspicion to stop Defendant; and (2) therefore, the circuit court did not err by denying Defendant's motion to suppress. View "State v. Williams" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of second-degree murder and sentencing him to ninety years in prison, holding that Defendant's discretionary sentence did not offend the Eighth Amendment's prohibition against cruel and unusual punishment.Defendant pled guilty to second-degree murder. He was seventeen years old when he committed the crime. The circuit court sentenced Defendant to ninety years in prison, making him eligible for parole at age sixty-two. On appeal, Defendant argued that his sentence was unconstitutional because it violated categorical Eighth Amendment sentencing restrictions for juveniles and because it was disproportionately harsh. The Supreme Court disagreed, holding (1) because the court did not sentence Defendant to a mandatory life sentence and sufficiently considered his youth when fashioning his sentence, there was no Eighth Amendment violation; and (2) Defendant did not meet the initial requirement to show that his sentence was grossly disproportionate to his crime. View "State v. Quevedo" on Justia Law

The Supreme Court reversed Defendant's the order of the circuit court granting Defendant's motion to suppress evidence obtained as a result of Defendant's arrest, holding that the circuit court erred when it refused to consider the application of the attenuation doctrine and suppressed the evidence.Defendant was charged with possession of methamphetamine and false impersonation. Before trial, Defendant moved to suppress the evidence obtained as a result of her interaction with police officers on the grounds that the officers lacked reasonable suspicion to detain her. The circuit court granted the motion to suppress. Despite the State's argument that the attenuation doctrine applied, the circuit court did not analyze the applicability of the attenuation doctrine. The Supreme Court reversed, holding that because the connection between Defendant's detention and the subsequent search was interrupted by the discovery of the existence of a valid, preexisting and unrelated warrant, the attenuation factors weighed in favor of the State. View "State v. Mousseaux" on Justia Law

The Supreme Court affirmed Defendant's sentence of eighty years imprisonment with forty years suspended for first-degree manslaughter, holding that the sentence was not grossly disproportionate to the offense and did not violate the Eighth Amendment.Specifically, the Supreme Court held (1) Defendant's sentence was not grossly disproportionate to the offense of first-degree manslaughter under the Eighth Amendment; (2) at sentencing, the circuit court properly examined the events surrounding the offense, Defendant's character and history, and Defendant's rehabilitation prospects; and (3) the circuit court did not abuse its discretion in crafting the sentence. View "State v. Holler" on Justia Law

The Supreme Court affirmed the decision of the circuit court affirming the assessed value of Appellants' agricultural land by the Meade County Commission sitting as a board of equalization (the Board), holding that the circuit court did not err.Before the Board, Appellants argued that the director of equalization incorrectly applied statutory provisions to determine their land's production value. The Board further adjusted the assessment from an average of $519 per acre down to an average of $512 per acre. Appellants appealed the Board's decision to circuit court. After a trial de novo, the circuit court affirmed the Board's tax assessment of the property. The Supreme Court affirmed, holding that the circuit court did not err when it determined that (1) the Board complied with the statutory provisions for evaluating agricultural land in their assessment of Appellants' property; and (2) the Board's tax assessment of the property did not violate provisions of the South Dakota Constitution that require uniform taxation at no more than its actual value. View "Trask v. Meade County Commission" on Justia Law