State v. Angle, 958 N.W.2d 501

Natalie Angle drove an SUV that crossed the center line on Highway 34 and struck an oncoming pickup; the pickup driver, James Birgen, was ejected and died from his injuries.
Officers at the scene smelled alcohol; Angle admitted to drinking while still in her vehicle before emergency personnel extracted her.
Two blood samples taken ~2 and ~3 hours after the crash showed BACs of .243 and .220; a chemist opined Angle’s BAC at the time of the crash was ~.274.
At the hospital Deputy Lanning read an extemporaneous Miranda warning omitting any explicit statement that counsel would be appointed if indigent; Angle then answered questions and later was arrested.
Angle was indicted for vehicular homicide and DUI, tried to the court after waiving a jury, convicted, and sentenced. She appealed, arguing suppression of the hospital statements and insufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were Angle’s hospital statements admissible given the Miranda advisory?	Warnings were functionally sufficient because Angle was told she had the right to an attorney and could stop questioning.	Miranda warnings were incomplete because officer omitted the right to appointed counsel; suppression required.	Miranda requires notice of appointed counsel; officer omitted that right. The suppression denial was error, but the error was harmless.
Was the evidence sufficient to sustain convictions for vehicular homicide and DUI (SDCL 32-23-1(1))?	Evidence (stipulated chemist opinion, blood test results, accident reconstruction, eyewitness) proved BAC ≥ .08 and negligence causing death.	Argues state failed to prove she was under the influence at the time of crash.	Evidence was overwhelming without the hospital statements; convictions affirmed and judgment of acquittal denial upheld.

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes custodial warning requirements, including right to appointed counsel)
California v. Prysock, 453 U.S. 355 (1981) (Miranda does not require rigid, verbatim script; functional equivalence suffices)
Rhode Island v. Innis, 446 U.S. 291 (1980) (defines interrogation and functional equivalents)
Florida v. Powell, 559 U.S. 50 (2010) (warnings must reasonably convey the required rights)
Duckworth v. Eagan, 492 U.S. 195 (1989) (substance of warnings, not exact wording, controls Miranda adequacy)
Oregon v. Elstad, 470 U.S. 298 (1985) (Miranda exclusionary rule is prophylactic and may require suppression even absent Fifth Amendment violation)
California v. Beheler, 463 U.S. 1121 (1983) (not all questioning outside station house is custodial)
State v. Willingham, 933 N.W.2d 619 (S.D. 2019) (discusses Miranda advisory practices by S.D. officers)
State v. Ralios, 783 N.W.2d 647 (S.D. 2010) (Miranda inquiry focuses on whether warnings reasonably conveyed rights)
State v. Lewandowski, 921 N.W.2d 915 (S.D. 2019) (harmless-error analysis when unlawfully obtained statements present but independent evidence is overwhelming)