State v. Reinhardt

Summary

The South Dakota Supreme Court affirmed Troy Lee Reinhardt’s simple-assault conviction and habitual-offender sentence. The court held that Reinhardt was not entitled to a definitive ruling on his requested self-defense instruction at the close of the State’s evidence because jury instructions are settled at the close of all evidence. The court also held that admission of fingerprint cards from prior Iowa and Nebraska arrests did not violate the Sixth Amendment Confrontation Clause because the cards were non-testimonial physical evidence.

Holdings

1. A defendant is not entitled to settlement or a definitive ruling on a requested jury instruction mid-trial at the close of the State's evidence; under SDCL 23A-25-4, instructions are settled at the close of all evidence and before final argument.
2. Fingerprint cards generated as a routine administrative step incident to arrest are physical, non-testimonial evidence and their admission does not violate the Sixth Amendment Confrontation Clause.

Questions Presented

1. Whether the circuit court was required to make a definitive ruling on Reinhardt's requested self-defense jury instruction at the close of the State's evidence.
2. Whether admission of certified fingerprint cards from prior arrests violated Reinhardt's Sixth Amendment Confrontation Clause rights.

Disposition

affirmed