South Dakota Supreme Court
State v. Reeves
November 18, 20212021 S.D. 64
Summary
The South Dakota Supreme Court affirmed the circuit court's admission of jail surveillance video, holding that the video was properly authenticated under the silent witness theory using a flexible, fact‑based approach, and therefore no abuse of discretion occurred.
Holding
- Whether the circuit court abused its discretion in admitting the jail’s surveillance video by failing to lay an adequate foundation to authenticate the footage.. The circuit court did not abuse its discretion; the video was properly authenticated under SDCL 19‑19‑901 and the silent witness theory.
Docket 29283
Cited authorities
- Fed. R. Evid. 901(b)(9)
- Fed. R. Evid. 901(b)(9)