State v. Ceplecha, 940 N.W.2d 682

On Nov. 11–12, 2016 Daniel Ceplecha and his son Rangler hosted drinking guests; an argument with Moses Red Bear over alleged theft escalated and both men shot Red Bear multiple times.
Eyewitness Wiley Yellow Hawk observed the events, heard admissions and threats, helped clean up blood, and reported the crime; Red Bear’s burned body was later found dumped roadside.
Daniel and Rangler were indicted for murder and conspiracy; over a year later they entered plea agreements and pled guilty to first-degree manslaughter (State dismissed murder counts); pleas reserved sentencing to the court.
About three months after pleading guilty they sought substitute counsel and moved to withdraw their pleas, asserting coercion, ineffective counsel, and claims of self-defense/actual innocence.
The circuit court held evidentiary hearings, found both pleas were knowing and voluntary, denied substitution and withdrawal motions, and sentenced each to life imprisonment without parole; the South Dakota Supreme Court consolidated and affirmed the appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Motion for substitute counsel (Rangler)	No good cause shown; denial proper	Counsel refused to listen; breakdown in communication; competency eval forced	Denial affirmed: alleged defects occurred pre-plea (waived); alternative: no good-cause showing and substitution would disrupt process
Motion to withdraw guilty pleas	Pleas were knowing, voluntary after thorough colloquies; late, self-serving self-defense claims lack credibility; withdrawal would waste resources	Pleas involuntary/coerced; actual innocence/self-defense; entered plea to avoid life sentence; withheld evidence	Denial affirmed: defendants failed to show a "fair and just" reason; colloquies show voluntariness; belated, unsupported self-defense claims not credible
Sentencing to life (Eighth Amendment / abuse of discretion)	Sentence within statutory range and justified by egregious facts (multiple shots, body burned, concealment)	Life is cruelly disproportionate/abuse of discretion given backgrounds and age	Affirmed: no gross disproportionality under Eighth Amendment; sentencing court did not abuse discretion after weighing factors

State v. Cowley, 408 N.W.2d 758 (S.D. 1987) (guilty plea waives nonjurisdictional defects)
State v. Irvine, 547 N.W.2d 177 (S.D. 1996) (good-cause standard and inquiry for substitute counsel)
State v. Kvasnicka, 873 N.W.2d 705 (S.D. 2016) (factors for pre-sentencing plea withdrawal)
United States v. Hyde, 520 U.S. 670 (1997) ("fair and just" reason standard for plea withdrawal)
State v. Rice, 877 N.W.2d 75 (S.D. 2016) (Eighth Amendment gross-disproportionality framework)
Solem v. Helm, 463 U.S. 277 (1983) (comparative analysis for disproportionality review)
United States v. Porter, 405 F.3d 1136 (10th Cir. 2001) (waiver rule does not apply to defects arising after a plea)