Justia Constitutional Law Opinion Summaries

Under the Fourth Amendment, law enforcement may not require an arrestee to urinate into a specimen container as a search incident to a lawful arrest without a valid warrant.Defendant was convicted and sentenced for unauthorized ingestion of a controlled substance. On appeal, Defendant argued that the circuit court erred by denying his motion to suppress evidence produced through chemical analysis of a urine sample that law enforcement obtained without first obtaining Defendant’s consent or a warrant. After considering an arrestee’s legitimate expectation of privacy and the government’s competing interest in preserving evidence, the Supreme Court agreed, holding (1) law enforcement may not, without a warrant, require an arrestee to provide a urine sample as a search incident to arrest; and (2) therefore, the search in this case was unconstitutional, and the circuit court erred by denying Defendant’s motion to suppress. View "State v. Lar" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree murder and sentencing him to life imprisonment.On appeal, Defendant argued that the circuit court (1) violated his Sixth Amendment right of cross-examination by refusing to admit evidence that Defendant passed a polygraph examination for the purpose of impeaching another witness’s testimony; and (2) improperly admitted character evidence used against him. The Supreme Court held (1) South Dakota’s per se rule against admitting polygraph-test results does not violate the Sixth Amendment, and the circuit court did not abuse its discretion by excluding Defendant’s polygraph evidence; and (2) the circuit court did not err by admitting evidence of Defendant’s sexual liaisons with three other women in the days leading up to the victim’s death. View "State v. Bertram" on Justia Law

The Supreme Court affirmed the judgment of the circuit court, rendered after a jury trial, convicting Defendant of aggravated assault (domestic) and simple assault (domestic). On appeal, Defendant challenged the circuit court’s admission of evidence of alleged instances of prior domestic abuse and claimed that his trial counsel was constitutionally ineffective. The Supreme Court held (1) the circuit court did not err in admitting the other acts evidence; and (2) counsel was not so ineffective that it deprived Defendant of his constitutional rights to counsel and a fair trial. View "State v. Phillips" on Justia Law

Sally Richardson alleged that her husband Michael forced her to work as a prostitute during the course of their marriage. Sally also alleged that Michael emotionally, physically, and sexually abused her, causing both humiliation and serious health problems. Sally divorced Michael on the grounds of irreconcilable differences, reserving by stipulation the right to bring other nonproperty causes of action against him. Following the divorce, Sally brought suit against Michael, alleging intentional infliction of emotional distress (IIED). The court, bound by South Dakota Supreme Court precedent in Pickering v. Pickering, 434 N.W.2d 758, (S.D. 1989), dismissed Sally’s suit for failing to state a claim upon which relief can be granted. Pickering held IIED was unavailable as a matter of public policy when it was predicated on conduct leading to the dissolution of marriage. Finding that Pickering was “ripe for reexamination for a number of reasons,” the South Dakota Supreme Court overruled Pickering, and reversed and remanded dismissal of Sally’s suit. View "Richardson v. Richardson" on Justia Law

In 2016, Berton Toavs shot and killed his girlfriend Eliza Edgins and his friend Nathan Gann at Toavs’s home in Faith, South Dakota. Toavs and Edgins were in an off-and-on romantic relationship for some time, and Gann had been staying at Toavs’s home for approximately six weeks prior to the incident. During the time Gann had been staying with Toavs, a romantic relationship developed between Edgins and Gann. Gann and Edgins apparently planned to leave South Dakota and continue their relationship. After hearing this news, Toavs left the house, returning the following morning. Toavs and Edgins argued, ending with Toavs going to his bedroom, grabbing his .45 caliber Colt revolver, and shooting Edgins multiple times. He then shot Gann, who had been sleeping on the living room floor. Both Edgins and Gann died from the gunshot wounds. Toavs appeals his sentences issued on two counts of first-degree manslaughter, arguing the sentencing court abused its discretion in ordering him to serve two consecutive sentences of 110 and 100 years. According to Toavs, the sentencing court did not adequately consider whether Toavs was capable of rehabilitation prior to imposing the sentences. Finding no reversible error, the South Dakota Supreme Court affirmed Toavs’s sentences. View "South Dakota v. Toavs" on Justia Law

Clint Bolton was charged with alternative counts of simple assault, a class 1 misdemeanor. Pursuant to a plea agreement, the State filed an amended complaint charging disorderly conduct, a class 2 misdemeanor. Class 2 misdemeanors carry a maximum sentence of thirty days in jail or a $500 fine or both. The State also agreed to recommend a thirty-day jail sentence with all thirty days suspended. Bolton agreed to the plea agreement, and counsel entered a no contest plea to disorderly conduct on Bolton’s behalf. The magistrate court accepted the plea and imposed a thirty-day jail sentence. The court then suspended execution of that sentence on the condition that Bolton obey all laws and remain on good behavior for six months. Bolton’s attorney immediately objected to the sentence, arguing the court could not condition a suspended execution of sentence for a period longer than thirty days, the statutory maximum term of imprisonment for class 2 misdemeanors. The issue before the South Dakota Supreme Court was whether sentencing courts have the power to suspend execution of sentence on the condition of good behavior for periods longer than the authorized maximum term of imprisonment. The Court concluded sentencing courts indeed have such power because it has been delegated to them by the Constitution and the Legislature has not restricted it. View "South Dakota v. Bolton" on Justia Law

The Supreme Court affirmed the sentence imposed upon Defendant to a five-year penitentiary term while Defendant was serving a probationary sentence imposed in a different criminal file. On appeal, Defendant argued that the sentencing court imposed an illegal sentence when it placed him under the dual supervision of the judicial and executive branches. The Supreme Court held (1) the sentencing court erred when it placed Defendant under simultaneous supervision of two branches of government; but (2) because Defendant was currently only under the supervision of the executive branch, the sentence was constitutional. View "State v. Humpal" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of threatening a judicial officer and disorderly conduct arising from statements Defendant made in the Minnehaha County Courthouse. At the conclusion of a court trial, the circuit court ruled that Defendant’s statements were “true threats” rather than speech protected by the First Amendment. Defendant appealed, arguing that his statements were protected speech and therefore could not be the basis for criminal conduct. The Supreme Court disagreed, holding that Defendant’s statements at the courthouse were not protected speech but, rather, constituted true threats under the relevant factors. View "State v. Draskovich" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree murder and sentencing him to mandatory life in prison. The court held (1) the circuit court did not err in its evidentiary rulings that Defendant consented to the seizure of his property from the hospital and that the revocation of that consent did not require the return of his property; (2) the circuit court did not err in denying Defendant’s motion to suppress evidence seized at Defendant’s friend’s house; (3) the circuit court did not abuse its discretion when it admitted twenty-six autopsy photographs during the trial; (4) the circuit court did not err in denying Defendant’s motion for a new trial on his claim of improper burden shifting; and (5) the evidence was sufficient to support Defendant’s conviction. View "State v. Hemminger" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Landowners’ request that the State pay reasonable attorney’s fees and expenses pursuant to S.D. Codified Laws 5-2-18 and the Uniform Relocation Assistance and Real Property Acquisition Policies Act (URA), 42 U.S.C. 4601-4655, after Landowners prevailed against the State on their claim of inverse condemnation. On appeal, Landowners argued that they were entitled to recovery of attorney’s fees and litigation expenses under section 5-2-18 because they prevailed on their inverse condemnation claim, asserting that the legislature intended to adopt by reference the URA when it enacted section 5-2-18. The Supreme Court held that the circuit court did not err in denying Landowners’ motion for attorney’s fees and expenses because, while section 5-2-18 incorporates by reference the provisions of the URA, its application is permissive rather than mandatory. View "Long v. State" on Justia Law