Wright v. Young, 927 N.W.2d 116

Wright participated in a coordinated shoplifting incident in Mitchell and was indicted for grand theft (value alleged $2,750).
He pleaded guilty pursuant to a plea agreement (State agreed not to file habitual-offender/other charge), and the court established a factual basis at the plea colloquy.
Sentenced to five years; execution was suspended and Wright was placed on four years supervised probation with periodic jail time; probation later revoked and he was ordered to serve the five-year sentence with four years suspended and credit for time served.
Wright filed a petition for writ of habeas corpus alleging due process violations and ineffective assistance of counsel for not providing police reports and not advising on item values.
The circuit court held an evidentiary hearing, denied the habeas petition, and issued a certificate of probable cause in boilerplate form without specifying the issues or making a substantial showing of constitutional denial.
The Supreme Court dismissed Wright’s appeal for lack of jurisdiction because the certificate of probable cause failed to specify the issues or make the required showing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Supreme Court has jurisdiction to review denial of Wright's habeas petition	Wright argued his due process and ineffective-assistance claims raise appealable constitutional issues	State argued the appeal lacks jurisdiction because the circuit court's certificate of probable cause is inadequate	Dismissed for lack of jurisdiction: circuit court's certificate did not specifically state probable cause or identify issues, so appeal not authorized
Whether Wright could challenge his guilty plea and counsel's effectiveness in habeas	Wright asserted plea unsupported by evidence and counsel ineffective for withholding reports and not advising on values	State maintained guilty-plea challenges are not for habeas collateral attack and jurisdictional defect bars appeal	Court noted guilty-plea challenges generally not reviewable in habeas; did not reach merits due to lack of jurisdiction

Iannarelli v. Young, 904 N.W.2d 82 (S.D. 2017) (certificate of probable cause must specifically show a substantial denial of a constitutional right)
Lange v. Weber, 602 N.W.2d 273 (S.D. 1999) (certificate must indicate which issues satisfy the showing required for appeal)
Stoebner v. Konrad, 914 N.W.2d 590 (S.D. 2018) (appellate jurisdiction exists only as provided by statute)
Engesser v. Young, 856 N.W.2d 471 (S.D. 2014) (habeas is a limited collateral attack; scope of review constrained)