State v. Miller

Summary

The Supreme Court of South Dakota affirmed Chris Allen Miller’s convictions for second-degree murder and aggravated assault arising from the death and injuries of his infant son. The court held that the evidence was sufficient to support the convictions and that the circuit court did not abuse its discretion by admitting testimony from Miller’s jail cellmate concerning an alleged admission. The court also concluded that Miller waived his claim that the jury verdict was coerced by failing to object at trial.

Holdings

1. The evidence, viewed in the light most favorable to the prosecution, was sufficient for a rational trier of fact to find beyond a reasonable doubt that Miller inflicted the injuries that caused Jacob's death and thereby committed second-degree murder and aggravated assault.
2. The circuit court did not abuse its discretion by admitting Chaffin's testimony concerning Miller's alleged admission.
3. SDCL 19-14-22 and SDCL 19-14-23 did not apply to the writing because it was used to refresh Chaffin's memory before his investigative meeting, not before or during his trial testimony.
4. Miller waived his jury-coercion argument by failing to object in the circuit court, and the record did not establish plain error.

Questions Presented

1. Whether the evidence was sufficient to support Miller's convictions for second-degree murder and aggravated assault.
2. Whether the circuit court abused its discretion by admitting Billy Chaffin's testimony concerning Miller's alleged statement.
3. Whether a writing used to refresh Chaffin's memory before his meeting with an investigator was subject to production under SDCL 19-14-22 and SDCL 19-14-23.
4. Whether Miller's claim that the circuit court coerced the jury was preserved for appellate review.

Disposition

affirmed