State v. Strahl

Summary

The Supreme Court of South Dakota affirmed the grant of a new trial on James Robert Strahl's first-degree murder conviction. The court held that newly discovered evidence of the State's key witness's perjury convictions, although impeachment evidence, was sufficiently material and powerful to probably produce an acquittal on the first-degree murder charge. The court upheld the denial of a new trial on the separate grand theft conviction.

Holdings

1. Newly discovered impeachment evidence is not categorically barred from supporting a new trial. When the evidence is sufficiently powerful to eradicate the credibility of a key prosecution witness, is material to an essential element, and probably would produce an acquittal at the relevant degree of culpability, it may satisfy the newly discovered evidence standard.
2. The circuit court did not abuse its discretion in finding that the newly discovered perjury evidence was material and probably would have produced an acquittal on the first-degree murder charge.
3. The newly discovered evidence need not establish a probability of acquittal on every charge; it is sufficient that it probably would have produced an acquittal at the degree of culpability found by the jury.

Questions Presented

1. Whether newly discovered evidence that the State's key witness had committed perjury in an unrelated case could support a new trial even though the evidence was impeaching.
2. Whether the circuit court abused its discretion in finding that the new perjury evidence was material and probably would have produced an acquittal on the first-degree murder charge.
3. Whether the probability of acquittal had to extend to every charge or could be satisfied by a probable acquittal at the degree of culpability for which the defendant was convicted.

Disposition

affirmed