State v. Martin, 2015 SD 2

In May 2012 at a Sioux Falls campsite, Eugene Martin and Clint Cottonwood were with victim Robert Thunderhawk; a fatal beating occurred the next morning.
Cottonwood testified he observed Martin strike Thunderhawk with a shovel (short then long handle), heard repeated blows, and later saw Martin sit calmly and cover the body with a tarp.
Police found the victim partially hidden under a tarp, a broken-handled shovel near Martin’s chair, and a long-handled shovel by a freshly dug trench; medical testimony showed skull fractures consistent with blunt-force trauma.
Martin and Cottonwood were arrested; Cottonwood later pleaded guilty to aiding/abetting manslaughter; Martin was tried, convicted of first-degree murder, and sentenced to life without parole.
On appeal Martin challenged (1) admission of certain out-of-court statements/911 recording as hearsay and (2) sufficiency of evidence of premeditation for first-degree murder.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Cottonwood’s out-of-court statements and 911 recording	State: testimony and 911 recording were admissible; defense opened the door and recording admitted for non‑truth purpose	Martin: statements and recording were inadmissible hearsay and prejudicial	Court: No abuse of discretion — defense opened the door to much testimony; 911 admissible for context; admission not prejudicial
Sufficiency of evidence of premeditation for first-degree murder	State: evidence (use of shovel as lethal weapon, nature/sequence of attack, concealment efforts, provocation) supports premeditation	Martin: evidence insufficient to show premeditated design to kill	Court: De novo review—viewing evidence favorably to prosecution, a rational juror could infer premeditation; conviction affirmed

Supreme Pork, Inc. v. Master Blaster, Inc., 764 N.W.2d 474 (2009) (standard for reviewing evidentiary rulings and prejudice)
Gartner v. Temple, 855 N.W.2d 846 (2014) (abuse of discretion explained)
State v. Buchholtz, 841 N.W.2d 449 (2013) (party who opens the door cannot then challenge admission)
Veith v. O’Brien, 739 N.W.2d 15 (2007) (same principle on opening the door to evidence)
State v. Brende, 835 N.W.2d 131 (2013) (standard for sufficiency review)
State v. Carter, 771 N.W.2d 329 (2009) (sufficiency framework—view evidence in light most favorable to prosecution)
State v. Shaw, 705 N.W.2d 620 (2005) (same sufficiency principles)
State v. Owens, 643 N.W.2d 735 (2002) (premeditation may be inferred; concealment supports premeditation)
State v. Wright, 768 N.W.2d 512 (2009) (factors for inferring premeditation)
State v. Owen, 729 N.W.2d 356 (2007) (use of lethal weapon and killing manner weigh toward premeditation)
State v. Plenty Horse, 741 N.W.2d 763 (2007) (insufficiency standard: verdict stands unless no rational juror could convict)