Matter of Implicated Individual

2021 S.D. 61
CourtSouth Dakota Supreme Court
DecidedOctober 27, 2021
Docket29473
StatusPublished
Cited by19 cases

This text of 2021 S.D. 61 (Matter of Implicated Individual) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Matter of Implicated Individual, 2021 S.D. 61 (S.D. 2021).

Opinion

#29473-a-MES 2021 S.D. 61

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

IN THE MATTER OF AN APPEAL BY AN IMPLICATED INDIVIDUAL.

APPEAL FROM THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT MINNEHAHA COUNTY, SOUTH DAKOTA

THE HONORABLE JAMES A. POWER Judge

MARTY J. JACKLEY STACY R. HEGGE of Gunderson, Palmer, Nelson, & Ashmore, LLP Pierre, South Dakota Attorneys for appellant.

JEFFREY R. BECK Sioux Falls, South Dakota Attorney for appellee ProPublica.

JON E. ARNESON Sioux Falls, South Dakota Attorney for appellee Argus Leader.

ARGUED AUGUST 24, 2021 OPINION FILED 10/27/21 #29473

SALTER, Justice

[¶1.] A special agent of the South Dakota Division of Criminal Investigation

(DCI) sought several search warrants involving the Implicated Individual. The

circuit court approved the warrants, which, along with the supporting affidavits and

inventories, were filed with the clerk of courts. The circuit court sealed the search

warrant files at the agent’s request, but later reconsidered its authority to do so

after members of the press sought access to the files. The court ultimately ordered

the search warrants and corresponding inventories to be unsealed. The Implicated

Individual has appealed. We affirm.

Facts and Procedural History

[¶2.] On December 9, 2019, a DCI special agent requested a search warrant

seeking information relating to an email account associated with the Implicated

Individual. The circuit court issued the warrant the same day. On December 16,

2019, the search warrant, the affidavit in support of the search warrant, and the

verified inventory were all filed with the Minnehaha County Clerk of Courts.

[¶3.] On March 13, 2020, the DCI agent sought four additional search

warrants related to the Implicated Individual, all of which the circuit court issued. 1

The additional search warrants, the affidavits supporting the warrants, and the

verified inventories were also filed with the Minnehaha County Clerk of Courts.

The warrants were to be served upon internet or cellular data providers and were

not directed to the Implicated Individual or the Implicated Individual’s property.

1. The same circuit court judge reviewed all five of the search warrants at issue here.

-1- #29473

Pursuant to the DCI agent’s requests, the court entered separate orders prohibiting

disclosure of the fact that the search warrants had been executed. These non-

disclosure orders were also filed with the clerk.

[¶4.] For each of the five warrants, the DCI agent submitted an affidavit in

support of a request to seal the search warrant affidavit and the search warrant

itself. According to the agent, “[p]remature disclosure” of the information “could

unnecessarily impede any continuing investigation . . . .” The circuit court entered

orders in the individual search warrant files sealing each of the warrants and their

supporting affidavits.

[¶5.] In July 2020, a reporter employed by the news organization ProPublica

contacted the Second Circuit Court Administrator requesting access to the sealed

search warrant documents involving the Implicated Individual. Learning of this

request, the circuit court reflected on its authority to enter the earlier orders to seal.

Contrasting a Supreme Court rule governing access to court records with specific

statutory limitations on sealing search warrant records, the court emailed general

counsel for ProPublica and the South Dakota Attorney General’s Office to discuss

“the scope of [the court’s] authority to seal documents related to a search warrant

. . . .” During the ensuing email exchanges, the court learned that the Implicated

Individual was represented by counsel and subsequently provided an opportunity

for the Implicated Individual to participate in the court’s inquiry. 2

2. While the circuit court’s determination of its authority to seal the search warrant records was pending, it indicated its willingness to keep all communications confidential but advised counsel that their submissions to the court and their email exchanges may become publicly available in the (continued . . .) -2- #29473

[¶6.] In August 2020, a reporter for the Argus Leader, a regional daily

newspaper, contacted the circuit court requesting an opportunity to intervene in the

proceedings. 3 After conferring with the parties, the court granted the Argus

Leader’s request and allowed it to present its legal position regarding access to the

search warrant documents. Amid these proceedings, the court consolidated the five

search warrant files. 4

[¶7.] On August 19, 2020, the circuit court issued a protective order

prohibiting the Press from disclosing or publicly disseminating “any information

that is currently sealed that [it] obtains through its participation in these

proceedings.” The protective order was “intended to be consistent with previous

admonitions to counsel . . . to keep this matter confidential until the issues are

resolved.”

[¶8.] The circuit court established a briefing schedule and identified its

principal inquiry as “the scope of [the court’s] authority to seal the contents of a

________________________ (. . . continued) event the court determined it lacked the authority to seal the contents of the search warrant files.

3. ProPublica and the Argus Leader will be referred to jointly as “the Press.”

4. The Implicated Individual makes a passing reference to the Press’s “authority to be [parties] in this appeal” because both news organizations asked for the search warrant information without seeking formal intervention or through motion practice. However, the Implicated Individual does not seriously challenge the standing of either news organization. In context, it appears the circuit court was aware that its procedure for revisiting the question of its authority was somewhat informal, but it stated it was relying upon basic standards of fairness and the provisions of SDCL 15-15A-13, which allow it to “hear any objections [to restricting access to court records] from other interested parties . . . .”

-3- #29473

search warrant file[.]” 5 Following its initial contemplation regarding the topic, the

court specifically asked the parties to address the provisions of SDCL chapter 15-

15A, which restates Supreme Court Rule 05-05 regarding public access to court

records 6 and SDCL 23A-35-4.1, which is a specific statute addressing a court’s

limited authority to seal certain documents associated with a search warrant.

[¶9.] All parties submitted briefs, with the Press submitting jointly. On

October 7, 2020, the circuit court heard argument and issued an oral decision that

generally favored the Press’s request for information. The court determined that

SDCL 23A-35-4.1, by its express terms, prohibited a court from sealing the search

warrants and verified inventories. And though the statute authorized an order

sealing the affidavit in support of a search warrant, the court determined the

authority was temporal and ended with the termination of the relevant

investigation or the filing of an indictment or information. On this basis, the court

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Biteler
2025 S.D. 73 (South Dakota Supreme Court, 2025)
Lapin v. Zeetogroup
2025 S.D. 36 (South Dakota Supreme Court, 2025)
Interest of J.W.
2025 S.D. 38 (South Dakota Supreme Court, 2025)
Puffy's, LLC v. Dep't of Health
2025 S.D. 10 (South Dakota Supreme Court, 2025)
Remington v. Iverson
2025 S.D. 1 (South Dakota Supreme Court, 2025)
State v. Dietz
2024 S.D. 70 (South Dakota Supreme Court, 2024)
State v. Waldner
2024 S.D. 67 (South Dakota Supreme Court, 2024)
State v. Dakota Bail Bonds
2024 S.D. 44 (South Dakota Supreme Court, 2024)
Mohnen v. Estate of Mohnen
2024 S.D. 35 (South Dakota Supreme Court, 2024)
Mrose Development Co. v. Turner County Bd. of Commissioners
2024 S.D. 28 (South Dakota Supreme Court, 2024)
State v. Foshay
2024 S.D. 12 (South Dakota Supreme Court, 2024)
Uhre Realty v. Tronnes
2024 S.D. 10 (South Dakota Supreme Court, 2024)
Stockwell v. McCook County Board of Commissioners
2024 S.D. 2 (South Dakota Supreme Court, 2024)
Matter of Implicated Individual
989 N.W.2d 517 (South Dakota Supreme Court, 2023)
Schupp v. Division of Insurance
2023 S.D. 4 (South Dakota Supreme Court, 2023)
Hermanek-Peck v. Spry
2022 S.D. 60 (South Dakota Supreme Court, 2022)
Deiter v. Xl Specialty Ins. Co.
980 N.W.2d 229 (South Dakota Supreme Court, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2021 S.D. 61, Counsel Stack Legal Research, https://law.counselstack.com/opinion/matter-of-implicated-individual-sd-2021.