Justia Constitutional Law Opinion Summaries

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

The Supreme Court affirmed the judgment of the circuit court in favor of Landowners on their inverse condemnation claim against the State seeking damages and a permanent injunction due to flooding on Landowners’ properties. The court held (1) the circuit court did not err in refusing to dismiss Landowners’ inverse condemnation claims based upon the doctrine of sovereign immunity; (2) the circuit court did not err in its determination that the State’s actions caused water to invade and damage Landowners’ properties in violation of S.D. Const. art. VI, 13; (3) the State was not entitled to filed a cross-claim against the City of Sioux Falls for contribution under the Joint Tortfeasor Act; and (4) the State did not acquire a drainage easement over Landowners’ real estate. View "Long v. State" on Justia Law

The Supreme Court affirmed the habeas court’s denial of Appellant’s petition for habeas corpus relief.Appellant pleaded guilty but mentally ill to first-degree manslaughter and to second-degree rape. The circuit court imposed a 130-year sentence for first-degree manslaughter and a forty-five-year sentence for second-degree rape. The Supreme Court affirmed on appeal. Thereafter, Appellant filed a petition for habeas relief, arguing, inter alia, that he was deprived of effective assistance of counsel and was compelled to give testimony against himself where the court ordered a psychological examination and where his attorney failed to warn Appellant that statements made to the examiner could be used against him. The habeas court denied Appellant’s petition. The Supreme Court affirmed, holding (1) Appellant waived his Fifth Amendment right against self-incrimination by failing to invoke it during the psychological examination, and Appellant was not deprived of effective assistance of counsel; and (2) Appellant was not deprived of due process, nor was his counsel ineffective for failing to request a hearing to determine if Appellant should receive provisional institutionalization under S.D. Codified Laws 23A-27-42 View "Iannarelli v. Young" on Justia Law

The Supreme Court affirmed Defendant’s convictions of first-degree robbery and possession of a firearm by a convicted felon. Contrary to Defendant’s arguments on appeal, the court held (1) the State’s evidence was sufficient to corroborate accomplice testimony, and therefore, the circuit court did not err in denying Defendant’s motion for a judgment of acquittal; (2) even if the circuit court’s admission into evidence several challenged evidentiary items was in error, the error was harmless; (3) the circuit court did not violate Defendant’s right to confront and examine a witness whose out-of-court statements were admitted at trial; and (4) the circuit court did not abuse its discretion in imposing Defendant’s sentence. View "State v. Kihega" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Defendant’s motion to suppress evidence discovered after police officers executed a search warrant at Defendant’s home. During the search, officers found marijuana in Defendant’s van, which was parked outside the home. The circuit court ruled (1) Defendant did not have a personal, legitimate expectation of privacy in his friend’s home and therefore could not challenge the search; and (2) alternatively, the search did not violate Defendant’s Fourth Amendment rights. The Supreme Court affirmed, holding that the circuit court did not err when it denied Defendant’s motion to suppress because Defendant did not establish a protectable interest in the property searched. View "State v. Gaters" on Justia Law

The Supreme Court affirmed in part and reversed in part the denial of the circuit court’s motion to suppress the evidence obtained after law enforcement officers executed a search warrant for Defendant’s home and arrested Defendant. The officers obtained the warrant based on information gained from a pole camera installed without a warrant on a public street light to record Defendant’s activities outside of his home. On appeal, Defendant argued that the officers’ use of the pole camera without a warrant violated the Fourth Amendment. The Supreme Court held (1) the warrantless use of the pole camera, installed to observe Defendant’s activities outside his residence for a two-month period, constituted a search under the Fourth Amendment, and therefore, the officer that installed the camera was required to first obtain a warrant; but (2) the officer acted reasonably based on the facts of this case, and the circuit court did not err when it denied Defendant’s motion to suppress based on the good faith exception to the exclusionary rule. View "State v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting summary judgment for certain Internet sellers (Sellers) and enjoining the State from enforcing 2016 legislation extending the obligation to collect and remit sales tax to sellers with no physical presence in the state. Pursuant to the legislation, the State brought this declaratory judgment action seeking a declaration that Sellers, who had no physical presence in the state, must comply with the requirements of the 2016 legislation. The circuit court enjoined the State from enforcing the obligation to collect and remit sales tax against Sellers, observing its obligation to adhere to Supreme Court precedent prohibiting the imposition of an obligation to collect and remit sales tax on sellers with no physical presence in the State. The Supreme Court affirmed, holding that the circuit court correctly applied the law when it granted Sellers’ motion for summary judgment. View "State v. Wayfair Inc." on Justia Law

The Supreme Court affirmed Defendant’s convictions for eight offenses, rendered after a jury trial. The court held (1) the circuit court did not err in admitting certain out-of-court statements as res gestate evidence; (2) the evidence was sufficient to support Defendant’s conviction of possession of a controlled substance while armed with a firearm; (3) the evidence was sufficient to support Defendant’s conviction of simple assault on a law enforcement officer while armed with a firearm; and (4) the evidence was sufficient to support Defendant’s conviction of possession of a controlled substance. View "State v. Kiir" on Justia Law

Ronald Johnson, a South Dakota State Penitentiary correctional officer, was murdered by two inmates during an escape attempt. Lynette Johnson, individually and on behalf of Ronald’s Estate (collectively, Johnson) sued the Department of Corrections (DOC) and a number of its employees in state court, alleging, among other claims, a violation of substantive due process rights under the state and federal constitutions pursuant to 42 U.S.C. 1983. DOC removed the case to federal court. The federal court granted summary judgment to DOC on the grounds of qualified immunity and remanded the remaining claims back to state court. The Eighth Circuit Court of Appeals affirmed. After the case returned to state court, the circuit court granted DOC’s motion for summary judgment on Johnson’s remaining claims. The Supreme Court affirmed, holding (1) the circuit court properly dismissed Johnson’s intentional infliction of emotional distress claim; (2) no genuine issues of material fact existed as to Johnson’s fraudulent misrepresentation claim; and (3) the circuit court correctly determined that res judicata barred any constitutional due process claim arising under the South Dakota Constitution. View "Estate of Johnson v. Weber" on Justia Law