875 N.W.2d 25
S.D.2016Background
- Defendant Troy Reinhardt punched a detainee in the Minnehaha County Jail lobby and was charged with simple assault; the State presented victim, eyewitness, and jail staff testimony at a two-day jury trial.
- At the close of the State’s case the court initially declined to rule that the evidence warranted a self-defense jury instruction; defense counsel indicated Reinhardt would testify if the court refused to give the instruction then.
- Reinhardt testified and presented self-defense; at the close of all evidence the court gave a self-defense instruction and the jury convicted him of simple assault.
- In a subsequent bench trial on a habitual‑criminal information, the State introduced certified fingerprint cards from prior convictions in Iowa (2003) and Nebraska (2008); a crime‑lab examiner matched those prints to Reinhardt’s South Dakota prints and testified.
- Over Reinhardt’s Confrontation Clause objection, the court admitted the fingerprint cards and found the prior convictions proved, sentencing Reinhardt as a habitual offender.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendant was entitled to a definitive ruling on his requested self‑defense instruction at the close of the State’s case | State: Court followed SDCL 23A‑25‑4 requiring instructions be settled after close of evidence | Reinhardt: Needed an earlier ruling so he would not be forced to testify and open prior‑bad‑acts evidence | Court: No error; instruction need not be settled mid‑trial and was properly given after all evidence |
| Whether admission of out‑of‑state certified fingerprint cards violated the Sixth Amendment Confrontation Clause | State: Fingerprint cards are non‑testimonial business/administrative records admissible without live out‑of‑state witnesses | Reinhardt: He had right to confront those who prepared/collected the prints and the methodology used | Court: Fingerprint cards are non‑testimonial administrative records; Confrontation Clause not implicated; admission proper |
Key Cases Cited
- Crawford v. Washington, 541 U.S. 36 (statement by non‑testifying witness barred unless witness unavailable and defendant had prior opportunity for cross‑examination)
- Melendez‑Diaz v. Massachusetts, 557 U.S. 305 (forensic reports are testimonial when prepared for prosecution)
- Bullcoming v. New Mexico, 564 U.S. 647 (forensic report admission requires live testimony by analyst who prepared report)
- Maryland v. King, 569 U.S. 435 (fingerprinting is a routine administrative step incident to arrest)
- United States v. Williams, 720 F.3d 674 (8th Cir.) (fingerprint cards are business records and their admission does not violate the Confrontation Clause)