State v. Talla, 2017 SD 34

In October 2015, Janno Kollay Talla waited outside an apartment, entered armed with a six-inch folding knife intending to kill Danga Kotudi, and after stabbing Kotudi, stabbed Ammuna Gayya (the mother of his child), who died from a chest wound.
Talla fled the scene, returned to Minnesota, was arrested; evidence included blood on his pants, the knife, and belongings in his car; he admitted he intended to kill Kotudi.
He was indicted on multiple counts; pursuant to a plea agreement he pleaded guilty to first-degree manslaughter and attempted first-degree murder; other counts were dismissed and concurrent sentences were recommended but the State made no specific sentence recommendation.
After a presentence investigation, the circuit court sentenced Talla to concurrent terms: 25 years for attempted first-degree murder and life imprisonment for first-degree manslaughter.
Talla appealed, arguing the life sentence was an abuse of discretion because it was grossly disproportionate to other Minnehaha County manslaughter sentences and because it foreclosed meaningful rehabilitation or parole.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether life sentence for first-degree manslaughter was an abuse of discretion	State: sentence within statutory maximum and appropriate given facts and risks; court may prioritize deterrence/incapacitation	Talla: life sentence grossly disproportionate compared to local manslaughter sentences, especially Rice; denies realistic prospect of parole/rehabilitation	Court affirmed: sentence not an abuse of discretion; crime among most serious manslaughter offenses and court permissibly prioritized deterrence/incapacitation and found rehabilitation speculative
Whether comparative sentences (Rice) required lower term	State: Rice distinguishable—Rice involved different facts and less premeditation	Talla: Rice shows lesser sentence despite mitigating factors; he had limited criminal history and mitigating factors	Court: Rice not controlling; Talla’s premeditation, targeting of uninjured victim, and killing of an innocent person justified harsher sentence
Whether court erred in assessing rehabilitation prospects	State: sentencing court may find rehabilitation speculative based on defendant’s character and facts	Talla: court wrongly concluded rehabilitation was unlikely	Held: finding that rehabilitation was speculative was not clearly erroneous; court considered mitigating factors but reasonably prioritized other penological goals

State v. Rice, 877 N.W.2d 75 (S.D. 2016) (sentencing review and comparison of manslaughter sentences)
State v. Chipps, 874 N.W.2d 475 (S.D. 2016) (standard of appellate review for sentencing)
State v. Bruce, 796 N.W.2d 397 (S.D. 2011) (statutory ranges and sentencing discretion)
State v. Anderson, 546 N.W.2d 395 (S.D. 1996) (broad discretion in sentencing and multiple penological goals)
State v. Pulfrey, 548 N.W.2d 34 (S.D. 1996) (rehabilitation as factual question for sentencing court)
Harmelin v. Michigan, 501 U.S. 957 (1991) (Eighth Amendment principles and penological goals)