State v. Larson, 980 N.W.2d 922

Tristin Larson pushed two-year-old Easton Felix during care on April 16, 2020; Easton later suffered severe brain and retinal hemorrhages and died.
Larson initially lied (blamed the dog); recorded phone calls and a videotaped police interview captured Larson admitting he pushed Easton and describing the force used.
Larson wasMirandized at the start of the April 18 interview, responded “Um, yeah” to waive rights, and then gave detailed statements; he was arrested at interview’s end.
Larson moved to suppress, arguing his emotional distress made any Miranda waiver and confession involuntary; the circuit court found the interrogation custodial but held the waiver and confession valid and voluntary.
A jury convicted Larson of second-degree murder and aggravated battery of an infant; he was sentenced to concurrent terms (including life for murder). The South Dakota Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of Miranda waiver	State: Larson understood rights and waived them; answers and detailed responses show waiver	Larson: emotional distress rendered “Um, yeah” not a valid, knowing waiver	Waiver was knowing, voluntary, and intelligent; "Um, yeah" plus conduct sufficient to infer waiver
Voluntariness of confession	State: no police overreach; calm questioning; breaks; confession voluntary	Larson: emotional impairment overbore his will, so confession involuntary	Confession voluntary under totality; no police coercion or overbearing tactics evident
Sufficiency — second-degree murder	State: confession + medical/expert proof of violent acceleration-deceleration trauma show act imminently dangerous and depraved mind	Larson: single push was accidental; lacked depraved mind or intent to harm	Evidence sufficient; jury reasonably found push was reckless/violent evincing depraved mind
Sufficiency — aggravated battery of an infant	State: Larson acted recklessly in pushing with substantial risk causing serious brain/retinal injury	Larson: accident; carpeted room, no dangerous objects, no substantial risk	Evidence sufficient to prove recklessness and aggravated battery of an infant

State v. Willingham, 933 N.W.2d 619 (S.D. 2019) (standard of review for suppression rulings)
State v. Two Hearts, 925 N.W.2d 503 (S.D. 2019) (standards for proving valid Miranda waiver)
State v. Lewandowski, 921 N.W.2d 915 (S.D. 2019) (totality of circumstances for waiver including mental state)
State v. Ralios, 783 N.W.2d 647 (S.D. 2010) (interpreting affirmative ‘‘yeah’’ as valid waiver)
State v. Strozier, 834 N.W.2d 857 (S.D. 2013) (voluntariness inquiry: police conduct and suspect’s capacity to resist)
State v. Morato, 619 N.W.2d 655 (S.D. 2000) (overborne will test for involuntariness)
State v. Frias, 959 N.W.2d 62 (S.D. 2021) (sufficiency review and depraved-mind analysis for second-degree murder)
State v. Falkenberg, 965 N.W.2d 580 (S.D. 2021) (example where force evinced depraved mind)
State v. Harruff, 939 N.W.2d 20 (S.D. 2020) (use of force evidence supporting depraved mind)
State v. Miller, 851 N.W.2d 703 (S.D. 2014) (medical testimony tying injuries to non-accidental trauma supports murder charge)