State v. Scott, 829 N.W.2d 458

At 2:30 a.m. on July 16, 2011, Rapid City officer saw a shirtless Scott pulling a woman, Mesteth, across a parking lot and arrested him; Mesteth was severely injured.
Earlier that evening, Wenona De’Sersa found Scott and his brother drinking; Mesteth is the mother of Scott’s child; they all drank together.
During the event, Scott choked Mesteth, causing her to go limp, and then punched and kicked her, while De’Sersa attempted to intervene; the baby was in the vicinity.
Mesteth was treated at the hospital; injuries included extensive facial swelling, pain, and multiple wounds; she did not testify at trial.
A jury convicted Scott of aggravated assault and he admitted habitual-offender status; circuit court sentenced him to eleven years.
Scott challenged multiple trial errors on appeal, including voir dire, Batson, photographic evidence, expert testimony, cross-examination limits, and sufficiency of evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did voir dire questioning abuse discretion?	Scott argues the State educated jurors on domestic violence biases.	Scott contends voir dire improperly prompted commitments about trial outcomes.	No abuse; questions probed biases and impartiality without improper entrapment.
Batson challenge on Native American juror strike	State struck Juror Laroche without racial motivation, providing race-neutral reasons.	Strike was racially motivated to remove a Native American juror.	Remand to complete Batson analysis; insufficient on-record findings; determine whether purposeful discrimination occurred.
Admission of photographs of the victim	Photos were probative of injuries and connected to the charged act.	Balancing under Rule 403 was not conducted on the record; prejudicial.	Court did not abuse discretion; admissibility upheld, though explicit balancing not on the record.
Admission of domestic violence expert testimony	Expert testimony aided understanding of domestic violence dynamics.	Testimony was improper or unnecessary expert intrusion.	Issue deemed lacking merit; admission not shown to be error significant enough to reverse.
Sufficiency of evidence for conviction	Evidence supported that Scott engaged in aggravated assault.	Evidence challenged as insufficient to prove all elements.	Insufficient merit to reverse; other issues unresolved only as to Batson remand.

Batson v. Kentucky, 476 U.S. 79 (1986) (establishes the prima facie case and subsequent steps for racial discrimination in jury selection)
Purkett v. Elem, 514 U.S. 765 (1995) (third-step standard for evaluating race-neutral explanations)
Johnson v. California, 545 U.S. 162 (2005) (reaffirms Batson framework and burden-shifting mechanics)
Snyder v. Louisiana, 552 U.S. 472 (2008) (emphasizes deference to trial court credibility in Batson analysis)
State v. Miller, 429 N.W.2d 26 (S.D. 1988) (voir dire abuse-of-discretion standard)
State v. Owen, 2007 S.D. 21 (2007) (outlines Batson review in South Dakota context)
State v. Fool Bull, 2009 S.D. 36 (2009) (guidance on voir dire and juror impartiality considerations)
State v. Engesser, 2003 S.D. 47 (2003) (evidentiary rulings reviewed for abuse of discretion)
State v. Tiegen, 2008 S.D. 6 (2008) (constitutional and evidentiary review framework)