Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed Defendant’s judgment of conviction and sentence for third-degree rape, holding that the circuit court did not err in denying Defendant’s motion to suppress evidence obtained from a warrantless search of his garage, holding that Defendant was not seized for Fourth Amendment purposes at the beginning of his encounter with police deputies and that his consent to search the garage was voluntary.On appeal, Defendant asserted that he was unreasonably seized by deputies before the search took place, and therefore, any consent give to search the garage after the seizure was not voluntary. The Supreme Court disagreed, holding that the deputies’ actions were reasonable, Defendant was not seized as soon as the encounter began, and Defendant’s consent to search the garage was voluntary. View "State v. Rolfe" on Justia Law

The Supreme Court affirmed Defendant’s conviction of second-degree murder, holding that the circuit court did not err in denying Defendant’s motion to suppress evidence obtained as a result of an investigatory stop.Prior to trial, the circuit court denied Defendant’s motion to suppress the evidence obtained as a result of the stop, concluding that the arresting law enforcement officer had reasonable suspicion to initiate the investigatory stop. The Supreme Court affirmed, holding that the officer’s suspicion was not grounded on a mere hunch, that the officer articulated facts that supported the quantum of suspicion necessary to initiate an investigatory stop, and that, under the totality of the circumstances, the investigatory stop was based on reasonable suspicion within the meaning of the Fourth Amendment. View "State v. Chase" on Justia Law

The Supreme Court affirmed the judgment of the circuit court entering an amended judgment of conviction ordering Defendant’s sentences to run concurrently to his corresponding federal sentences, holding that Defendant had no Sixth Amendment right to counsel in the circuit court proceeding to correct his sentences.Defendant pleaded guilty to kidnapping and assault. Defendant was sentenced to life imprisonment for the kidnapping and thirty years for the assault. The circuit court ordered the sentences to run consecutively to corresponding federal sentences Defendant had received for the same offenses. The Supreme Court reversed and remanded the case for resentencing, holding that a South Dakota state court may not impose a consecutive sentence in state court when a defendant has been sentenced for the same offenses in federal court. After Defendant was resentenced, he argued that the circuit court’s failure to provide court-appointed counsel in the sentence correction proceeding violated his Sixth Amendment right to counsel. The Supreme Court disagreed, holding that the sentence correction proceeding was not a critical stage in which Defendant had a Sixth Amendment right to court-appointed counsel. View "State v. Red Kettle" on Justia Law

The Supreme Court dismissed the State’s intermediate appeal challenging the circuit court’s reversal of the magistrate court’s order denying Defendant’s motion to suppress, holding that there was no basis for an appeal to this Court at the present stage of the proceedings.Defendant was charged with driving under the influence of alcohol. Defendant filed a motion to suppress the evidence obtained from the traffic stop, arguing that police officers lacked reasonable suspicion. The magistrate court denied the motion. Defendant was then convicted and sentenced. Defendant appealed, and the circuit court reversed and remanded the judgment. The State petitioned for an intermediate appeal, arguing that the Supreme Court had jurisdiction to hear an appeal under S.D. Codified Laws 23A-32-5. The Supreme Court dismissed the appeal, holding that no appeal can lie from the circuit court’s remand order. View "State v. Sharpfish" on Justia Law

After the United States Supreme Court vacated the judgment of the Supreme Court affirming the circuit court’s summary judgment in favor of Defendants, the Supreme Court reversed the circuit court’s grant of summary judgment and remanded the case for proceedings consistent with the United States Supreme Court’s opinion.In 2017, the Supreme Court affirmed the circuit court’s summary judgment in favor of Defendants, holding that the statutory scheme requiring internet sellers with no physical presence in South Dakota to collect and remit sales tax violated the Commerce Clause. The United States Supreme Court vacated the judgment and remanded the case. The State subsequently filed a motion requesting the Supreme Court to remand the matter for further proceedings. Defendants filed no response. Accordingly, the Supreme Court dispositively remanded this case for further proceedings not inconsistent with the United States Supreme Court’s opinion. View "State v. Wayfair Inc." on Justia Law

The Supreme Court reversed Defendant’s conviction and sentence for possessing a controlled substance (methamphetamine), holding that the circuit court erred by denying Defendant’s motion to suppress evidence obtained from an illegal search and seizure.On appeal, Defendant argued that the search of his person violated the United States Constitution’s prohibition against unreasonable searches and seizures. The State did not obtain a warrant to search Defendant but argued that the search was valid as an investigatory stop under Terry v. Ohio, 392 U.S. 1 (1968). The Supreme Court disagreed, holding (1) because the State failed to identify a reasonable suspicion of criminal activity, Defendant’s search and seizure could not be justified under Terry; and (2) the consent exception to the Fourth Amendment’s warrant requirement did not apply in this case. View "State v. Kaline" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Defendant’s motion to suppress evidence on the grounds that the police officer lacked reasonable suspicion to initiate an investigatory traffic stop and that the search warrant for a blood sample was invalid under South Dakota law.Defendant appealed from an order entering a suspended imposition of sentence after he was found guilty of driving under the influence of alcohol. The Supreme Court affirmed the denial of Defendant’s motion to suppress, holding (1) the circuit court’s finding that the officer observed the vehicle cross the center line provide the officer reasonable suspicion to initiate the stop; and (2) the warrant obtained for Defendant’s blood draw did not violate the Warrants Clause of the South Dakota Constitution. View "State v. Bowers" on Justia Law

The Supreme Court affirmed the judgment of the habeas court denying Appellant’s petition for a writ of habeas corpus. After a jury trial, Appellant was convicted of second-degree murder and aggravated assault. In his habeas petition, Appellant argued that the circuit court committed errors during the jury selection process that warranted a new trial and that his counsel provided constitutionally ineffective assistance. The habeas court concluded (1) the circuit court committed errors during the jury selection process, but the errors were not structural and Appellant did not prove prejudice; and (2) Appellant failed to prove that counsel was ineffective during the jury selection process. The Supreme Court affirmed, holding (1) the circuit court’s errors during the jury selection process were not structural and were harmless; and (2) Appellant failed to show that he receive ineffective assistance of counsel. View "Miller v. Young" on Justia Law

The Supreme Court reversed the judgment of the circuit court granting Defendant’s motion to suppress evidence found in the vehicle Defendant was driving, holding that, contrary to the circuit court’s finding, Defendant’s traffic stop was not unlawfully extended.Defendant was indicted on four felony drug charges after controlled substances were found in the vehicle she was driving. The circuit court granted Defendant’s motion to suppress, determining that the officer that stopped the vehicle unlawfully prolonged the traffic stop to question Defendant, conduct standard field sobriety tests, and call for a drug dog without reasonable suspicion of drug activity. The Supreme Court reversed, holding that the officer’s decision to extend the initial traffic stop to question Defendant about drug activity and to conduct the drug dog sniff was supported by reasonable suspicion, and therefore, the traffic stop was not unlawfully extended. View "State v. Barry" on Justia Law

The Supreme Court reversed the judgment of the circuit court granting Defendant’s motion to suppress evidence found in the vehicle Defendant was driving, holding that, contrary to the circuit court’s finding, Defendant’s traffic stop was not unlawfully extended.Defendant was indicted on four felony drug charges after controlled substances were found in the vehicle she was driving. The circuit court granted Defendant’s motion to suppress, determining that the officer that stopped the vehicle unlawfully prolonged the traffic stop to question Defendant, conduct standard field sobriety tests, and call for a drug dog without reasonable suspicion of drug activity. The Supreme Court reversed, holding that the officer’s decision to extend the initial traffic stop to question Defendant about drug activity and to conduct the drug dog sniff was supported by reasonable suspicion, and therefore, the traffic stop was not unlawfully extended. View "State v. Barry" on Justia Law