844 N.W.2d 610
S.D.2014Background
- Hatchett was convicted of first-degree burglary and obstructing a law enforcement officer after fleeing from an officer into an occupied apartment and bolting the door.
- The jury found he entered with intent to obstruct the officer, a crime under SDCL 22-11-6, supporting the burglary charge.
- Hatchett challenged the predicate offense, the Batson claim, and the exclusion of a written letter as evidence.
- During voir dire, the State struck the only Native American juror, Hatchett raised a Batson challenge and the court reviewed it under a three-step test.
- A letter Hatchett wrote to the victims while in jail was partially redacted and, when offered by Hatchett, barred as hearsay; the State did not offer it, and the court denied its admission.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is obstructing police an adequate predicate offense for first-degree burglary? | Hatchett asserts obstructing is not a predicate. | Hatchett argues law should exclude reactive offenses from predicate scope. | Obstructing fits within 'any crime'; affirmed judgment on predicate. |
| Was the peremptory strike of the Native American juror racially motivated? | Hatchett contends Batson violation occurred. | State offered race-neutral reasons for striking J.D.S. | No purposeful discrimination; Batson not violated. |
| Did the trial court abuse its discretion by excluding Hatchett's letter as evidence? | Hatchett sought admission of the letter as evidence. | Letter is hearsay and not excused by any exception or estoppel. | Court did not abuse discretion; letter excluded as hearsay. |
Key Cases Cited
- State v. Miranda, 776 N.W.2d 77 (2009 SD) (statutory interpretation standard of review)
- State v. Roach, 825 N.W.2d 258 (2012 SD) (credibility in Batson decision; deference to trial court)
- Rice v. Collins, 546 U.S. 333 (2006) (burden on ultimate disproving race motive remains with defendant)
- Batson v. Kentucky, 476 U.S. 79 (1986) (propensity to strike jurors based on race violates equal protection)
- State v. St. Cloud, 465 N.W.2d 177 (SD 1991) (elements of judicial estoppel and credibility considerations)