South Dakota Supreme Court
State of South Dakota, Plaintiff and Appellee v. Troy Lee Reinhardt, Defendant and Appellant
February 3, 20162016 S.D. LEXIS 19
Summary
The South Dakota Supreme Court affirmed Reinhardt's conviction, holding that the trial court did not err in refusing a self‑defense instruction until the close of the State's case and that the admission of out‑of‑state fingerprint cards did not violate the Sixth Amendment Confrontation Clause because such cards are non‑testimonial physical evidence.
Holding
- Whether the trial court erred by not granting a definitive self‑defense jury instruction at the close of the State's evidence.. The trial court did not err; a self‑defense instruction may be given at the close of the evidence and the defendant is not entitled to a determinative ruling earlier.
- Whether the admission of certified fingerprint cards from other states violates the Sixth Amendment Confrontation Clause.. The fingerprint cards are non‑testimonial physical evidence and their admission does not violate the Confrontation Clause.
Docket 27194
Cited authorities
- U.S. Const. amend. VI