State v. Solis, 931 N.W.2d 253

Solis and his girlfriend Lexie Sanchez lived together; police responded to two separate domestic incidents on April 23, 2017 and July 19, 2017 involving alleged assaults by Solis on Sanchez.
April incident: Sanchez reported being struck in the head with a broom, choked, and having plastic embed in a facial laceration; medical personnel treated lacerations and a hematoma.
July incident: Sanchez alleged repeated hitting, kicking, being struck with a bottle, threatened and lunged at with a blue-and-black knife; officers later found a blue-and-black knife on Solis.
Two separate grand jury indictments charged multiple counts including aggravated assault (by choking and by dangerous weapon) and several simple assaults; part II informations alleged prior convictions.
The State moved to join the two indictments for trial; the circuit court granted joinder (except for a conditional-bond charge) and a jury convicted Solis of aggravated assault with a dangerous weapon (broom) and multiple simple-assault counts.
Solis appealed, arguing (1) joinder was improper and prejudicial, and (2) insufficient evidence supported aggravated assault by a dangerous weapon.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court erred by joining the two indictments for trial	Joinder was unfairly prejudicial; incidents were months apart, different methods, not same act/plan	State: same victim, same location, 87 days apart, similar methods; evidence shows a common scheme in domestic-abuse context	Court affirmed joinder — no abuse of discretion; joinder appropriate under SDCL 23A-6-23 and prejudice not shown
Whether evidence was sufficient for aggravated assault by a dangerous weapon (plastic broom)	Broom not designed to inflict death/serious harm and evidence insufficient to show it was used in manner likely to inflict serious bodily harm	State: broom broke and piece embedded in Sanchez’s face; injuries and embedded plastic support inference weapon used in manner likely to cause serious harm	Court affirmed denial of acquittal — evidence (embedded plastic, lacerations, hematoma, stitches) sufficed to show broom used in manner likely to inflict serious bodily harm; serious bodily injury need not be proved under SDCL 22-18-1.1(2)

State v. Goodshot, 897 N.W.2d 346 (joinder standard and prejudice burden)
State v. Loftus, 573 N.W.2d 167 (joinder when offenses closely related in time, location, manner)
State v. Phillips, 906 N.W.2d 411 (admissibility of prior domestic abuse to show relationship and motive)
State v. Laible, 594 N.W.2d 328 (prior familial abuse admissible under Rule 404(b) to explain interactions)
State v. Janisch, 290 N.W.2d 473 (distinguishable; involved different aggravated-assault subsection requiring serious bodily injury)