South Dakota Juvenile Sentencing in Charles Case Upheld as Constitutional
PIERRE S.D. – Attorney General Marty Jackley announces that the South Dakota Supreme Court has held that South Dakota’s amended Juvenile Statutory Sentencing Scheme complies with U.S. Supreme Court Case Law and affirms Daniel Charles’ sentence for his role in the murder of Duane Ingalls.
“The South Dakota Supreme Court has upheld our legislative changes to juvenile sentencing that strike a balance with fairness and accountability. While the lengthy sentence does provide a future opportunity for early release on parole, it accounts for this horrific crime and is necessary to protect the public,” said Jackley.
On April 17, 2000, fourteen-year-old Daniel Charles was convicted by a jury of first degree murder for the 1999 death of his stepfather Duane Ingalls. With a high powered rifle, Charles laid in wait behind his upstairs bedroom window, watching for his stepfather. When Ingalls returned home, Charles shot him in the head. The South Dakota Supreme Court upheld Charles’ conviction, relying on testimony from the trial, showing “Charles indicated he purposely killed Ingalls,” and that “Charles had contemplated other ways to kill Ingalls.” The Court noted that the jury also heard “testimony that Charles dragged Ingalls’ body into the garage and shut the door, cleaned the blood off the sidewalk and cleaned the clothing he had worn.”
Following Charles’ sentence, the United States Supreme Court in a trio of cases including Miller v. Alabama, 132 S.Ct. 2455, (2012), held that the Eighth and Fourteenth Amendments to the U.S. Constitution forbid sentencing schemes that mandate life in prison without parole for juvenile offenders. Based upon the United States Supreme Court decisions, Charles filed a motion to correct his unconstitutional sentence. In 2015, the sentencing court resentenced Charles to 92 years in prison. Charles then appealed to the South Dakota Supreme Court.
The South Dakota Supreme Court’s review of the evidence and oral ruling, affirm that the sentencing court properly applied the law in Miller to Charles in particular before it imposed a harsh penalty. The sentencing court specifically acknowledged “the lessened moral culpability associated with the mitigating qualities of youth, “but gave more weight to its finding that Charles “still presents a condition of moral atrophy” and that the evidence supports that Charles acknowledged that “he continues to manipulate,” “explodes in anger if his buttons are pushed,” and has “only recently stopped lying.” The court also gave weight to the gravity of the offense, finding it to be a “premeditated, deliberate, intentional, sniper killing.”