State v. Abraham-Medved, 4 N.W.3d 436

Tashina Abraham-Medved pled guilty in South Dakota to unauthorized ingestion of a Schedule I or II controlled substance, under a plea that allowed both sides to argue sentence and left sentencing to the court’s discretion.
While released on bond, Abraham-Medved failed to attend her presentence investigation (PSI) interview or the initial sentencing hearing, leading to a bench warrant and her eventual arrest.
At her sentencing, her court-appointed counsel (Doody) moved to withdraw due to a severe breakdown in communication with Abraham-Medved; the motion was summarily denied without inquiry by the court.
Abraham-Medved ultimately represented herself at sentencing, making requests for probation, concurrent sentencing, and treatment, but her counsel made minimal arguments on her behalf.
The court sentenced her to 5 years in prison (2 years suspended), departing from presumptive probation; her subsequent appeal challenges the denial of her counsel's withdrawal request.
On appeal, Abraham-Medved argued she was prejudiced by the lack of opportunity to demonstrate good cause for new counsel and ineffective representation at sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the court err in denying counsel’s	The breakdown in communication alone	Required a chance to explain good cause;	Yes; denial without inquiry was abuse of discretion.
motion to withdraw without inquiry?	did not warrant inquiry or withdrawal.	she and counsel were not allowed to do so.
Was Doody's performance prejudicial to	No prejudice shown; likely same result.	Prejudiced: left to fend for herself,	Yes; reasonable probability of different outcome but
the outcome of sentencing?		inadequate advocacy at sentencing.	for counsel’s deficient performance.
Was there a need to remand for a good-cause	Not necessary given record or	Remand for a hearing, or for resentencing	No; direct remand to new sentencing as subsequent
hearing?	subsequent appointment of new counsel.	with new counsel required.	events made it unnecessary.
What is the correct standard for abuse of	Asked court to clarify case law	Sided with recent standard from Delehoy.	Clarified both main iterations are equivalent, focus on
discretion review?	definitions of 'abuse of discretion.'		arbitrary, unreasonable, or unsupported decisions.

State v. Loftus, 566 N.W.2d 825 (S.D. 1997) (abuse of discretion review of withdrawal of counsel motions)
State v. Iron Necklace, 430 N.W.2d 66 (S.D. 1988) (adopting standard for substitute counsel only upon good cause without unreasonable disruption)
State v. Martinez, 882 N.W.2d 731 (S.D. 2016) (right to meaningfully present cause for new counsel at sentencing; ineffective representation at sentencing warrants reversal)
State v. Fender, 484 N.W.2d 307 (S.D. 1992) (court must meaningfully inquire when counsel withdrawal is sought)
State v. Delehoy, 929 N.W.2d 103 (S.D. 2019) (clarifying modern standard for abuse of discretion review)