PIERRE, S.D. (KELO) — A Jerauld County man must serve the rest of his lifetime in prison, the South Dakota Supreme Court has ruled.
In an opinion publicly released Thursday, the state’s high court rejected the claim of Mitch Leroy Caffee that his life sentence for first-degree manslaughter and aggravated assault was too severe.
Caffee pleaded guilty to shooting his wife’s grandmother in the face and killing her with a .40-caliber pistol in her Wessington Springs home sometime after 2 a.m. on October 24, 2021.
His wife was staying at the grandmother’s home. He went there because his wife had filed another protection order against him. Caffee took his wife hostage. He shot the grandmother when she tried to call 911. He surrendered after a six-hour standoff with law enforcement.
Circuit Judge Patrick Pardy sentenced Caffee to life in prison without the possibility of parole. Caffee’s attorneys, David Wheeler and Alyssa Horn of Huron, argued that only three of 94 manslaughter convictions in the past 10 years resulted in life sentences and that his crime was committed unintentionally.
The five Supreme Court justices unanimously disagreed that Caffee’s sentence violated the U.S. Constitution’s ban on cruel and unusual punishment. Justice Janine Kern wrote the opinion.
“In this case, although Caffee had no prior convictions, the particular circumstances surrounding this crime do not lessen its gravity. First, Caffee broke into (the grandmother’s) home at night. Then, he was violent toward her granddaughter—who was staying there specifically because he had already violated a no-contact order and she no longer felt safe in her own home. Finally, Caffee admits that it was his intent to use his pistol to knock the phone out of the ninety-year-old woman’s hand, which he did with his finger on the trigger of the loaded firearm. On the spectrum of all criminality, therefore, the gravity of Caffee’s crime is high,” the justice stated.
She added, “The circuit court described Caffee’s intentional conduct in shooting (the grandmother) in the face, which is among the most serious commissions of this offense. Thus, when compared to the gravity of Caffee’s offense, his punishment is not grossly disproportionate, and our review of his constitutional claim ends.”
Caffee’s attorneys also claimed that the judge abused his discretion in sentencing him to life without the possibility of parole. Judge Pardy had said Caffee’s history didn’t suggest that his prospects for rehabilitation were good: “The fact is that your violence towards women, with a history of abuse and terrorizing your wife, choking a domestic partner to the point of blackout, is a serious red flag for future violence. And I do believe that you will always be a danger to the women in your life.”
Justice Kern found that Judge Pardy was within his discretion in determining that “Caffee’s
rehabilitation was not a factor the court could accommodate without jeopardizing the safety and well-being of the community.”
Justice Kern concluded, “Caffee does not point to anything the court failed to consider—he
simply disagrees with how the court weighed the factors it considered. Our review of the record shows that there were ample aggravating factors to support affirmance of the court’s decision to impose a life sentence without the possibility of parole.”