State v. Mitchell

963 N.W.2d 326, 2021 S.D. 46
CourtSouth Dakota Supreme Court
DecidedAugust 4, 2021
Docket29194
StatusPublished
Cited by12 cases

This text of 963 N.W.2d 326 (State v. Mitchell) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Mitchell, 963 N.W.2d 326, 2021 S.D. 46 (S.D. 2021).

Opinion

#29194-r-MES 2021 S.D. 46

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

STATE OF SOUTH DAKOTA, Plaintiff and Appellee,

v.

JAMESON CHARLES MITCHELL, Defendant and Appellant.

APPEAL FROM THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT YANKTON COUNTY, SOUTH DAKOTA

THE HONORABLE CHERYLE GERING Judge

JASON R. RAVNSBORG Attorney General

ERIN E. HANDKE Assistant Attorney General Pierre, South Dakota Attorneys for plaintiff and appellee.

KEVIN J. LOFTUS of Kennedy, Pier, Loftus & Reynolds, LLP Yankton, South Dakota Attorneys for defendant and appellant.

CONSIDERED ON BRIEFS MAY 27, 2020 OPINION FILED 08/04/21 #29194

SALTER, Justice

[¶1.] After a brief confrontation with Lucas Smith at a local bar, Jameson

Mitchell armed himself with a handgun and encountered Smith in a nearby alley.

Smith ran toward Mitchell, shouting for Mitchell to shoot him. After taking a few

steps back, Mitchell fired at the charging Smith, fatally wounding him. Pursuant to

a plea agreement with the State, Mitchell pled guilty to first-degree manslaughter

under the theory that he was “resisting an attempt by the person killed to commit a

crime.” The circuit court imposed a 124-year prison sentence. We vacate the

sentence and remand for resentencing.

Background

[¶2.] Jameson Mitchell (Mitchell) approached Lucas Smith (Smith) and

Smith’s friend, Jamie White (White), in the game room at Mojo’s bar in Yankton

shortly after midnight on April 6, 2019. Mitchell had consumed six, 16-ounce beers

earlier in the evening and allegedly confronted the couple because he believed

Smith had been making negative comments about him to others.

[¶3.] Video surveillance from Mojo’s shows Mitchell approaching Smith and

White, who were sitting near a pool table. Both Smith and White stood up and a

brief physical skirmish ensued, though it is difficult to determine which party acted

first. A bystander attempted to intervene before White grabbed Mitchell by the hair

and pulled him around the game room. Bar employees responded by removing all

three individuals, escorting Mitchell to one door and Smith and White to another.

[¶4.] Although not revealed by the surveillance video, tensions apparently

flared again outside of Mojo’s, prompting bar employees to order Mitchell, Smith,

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and White to leave the property entirely or face a response from law enforcement.

White followed Smith to a friend’s unlocked car parked in a nearby parking lot.

White later related that Smith was extremely distraught and expressed suicidal

thoughts while the two were in the car. In her testimony before the grand jury,

White stated that once inside the car, Smith “started screaming and punching and

yelling that he just wanted to die and that he didn’t want to be here anymore . . . .”

They got out of the car a short while later because Smith indicated he “needed to

breathe[,]” and they saw Mitchell in the alley.

[¶5.] After his involuntary departure from Mojo’s bar, Mitchell went back to

his apartment where he retrieved a .38 caliber revolver. He later claimed the

revolver was for protection, and said he was on his way to go out to eat with friends

at a local restaurant. However, he first went to the alley near Mojo’s where he

again encountered Smith.

[¶6.] Surveillance video from a nearby auto body shop showed a portion of

the confrontation between the two young men from two separate camera angles. At

approximately 12:45 a.m., the recorded video footage shows Mitchell entering the

alley from the right moving to the left. Initially, Mitchell is seen jogging and

skipping while holding his gun. Mitchell soon slows his gait but continues

advancing and points the gun directly in front of him.

[¶7.] Moments later, Smith bursts into the left side of the camera’s view,

running full speed at Mitchell. A subsequent investigation revealed that Smith

yelled, “shoot me” as he was running toward Mitchell. Mitchell is seen taking a few

steps back with his gun pointed at Smith. With Smith very near and closing fast,

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Mitchell fires three shots in rapid succession. After the first two shots, Smith is

seen veering off to the right and running outside of the camera’s view while Mitchell

leaves in a different direction. The entire sequence of events transpired in less than

20 seconds.

[¶8.] The body shop surveillance video also shows Smith staggering back

into the camera’s view from the right before falling to the ground where White

comes to attend to him. White immediately called for help, and law enforcement

officers and emergency medical personnel arrived a short time later. Smith was

transported to a local hospital where he died from a single gunshot wound to the

chest later that morning, on his 24th birthday. 1

[¶9.] Law enforcement officers quickly located Mitchell and arrested him. A

Yankton County grand jury returned an indictment charging Mitchell with first-

degree murder, alleging he killed Smith “with a premeditated design to effect [his]

death.” See SDCL 22-16-4(1). Mitchell pled not guilty, and in a May 2019

submission to the circuit court, defense counsel indicated the possibility of a self-

defense claim based, in part, upon the “history between [Mitchell] and [Smith].” 2

[¶10.] The relationship between the two men was, in fact, long-standing and

complicated. Mitchell and Smith had known each other since elementary school.

Mitchell reported several specific instances in which the older Smith bullied him,

sometimes using physical violence. As adults, Mitchell had briefly lived with Smith

1. Mitchell was 22 years old at the time of the shooting.

2. The statement came in the affidavit of Mitchell’s lawyer in support of a motion seeking the appointment of a defense investigator, which the circuit court later granted.

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and White, who were romantically involved at various times for several years.

However, it appears the temporary living arrangement was more a consequence of

White’s relationship with Mitchell’s girlfriend at the time, not a separate friendship

with Mitchell.

[¶11.] The parties engaged in plea negotiations and reached a plea agreement

under which the State agreed to dismiss the indictment alleging first-degree

murder, and Mitchell agreed to plead guilty to an information charging him with

first-degree manslaughter. The parties selected the statutory theory of criminal

liability set out in SDCL 22-16-15(4) which describes manslaughter in the first

degree as “[h]omicide . . . perpetrated . . . [u]nnecessarily, either while resisting an

attempt by the person killed to commit a crime or after such attempt has failed.”

(Emphasis added). The plea agreement provided that the State would recommend a

maximum prison sentence of 60 years, but further stated that “[t]he victim’s family

will be free to make any recommendation they wish and the defense will have an

open recommendation.”

[¶12.] At the change of plea hearing, the circuit court asked about the

reasons for the plea agreement, and the prosecutor and Mitchell’s counsel both

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Bluebook (online)
963 N.W.2d 326, 2021 S.D. 46, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mitchell-sd-2021.