Matter of Implicated Individual

989 N.W.2d 517, 2023 S.D. 16
CourtSouth Dakota Supreme Court
DecidedApril 5, 2023
Docket30063
StatusPublished
Cited by1 cases

This text of 989 N.W.2d 517 (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, 989 N.W.2d 517, 2023 S.D. 16 (S.D. 2023).

Opinion

#30063-a-SRJ 2023 S.D. 16

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

STACY R. HEGGE of Gunderson, Palmer, Nelson & Ashmore, LLP Pierre, South Dakota

TALBOT J. WIECZOREK of Gunderson, Palmer, Nelson & Ashmore, LLP Rapid City, South Dakota Attorneys for appellant Implicated Individual.

ARGUED MARCH 23, 2023 OPINION FILED 04/05/23 PAUL S. SWEDLUND Solicitor General Pierre, South Dakota Attorney for appellee State of South Dakota.

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

JON E. ARNESON Sioux Falls, South Dakota Attorney for appellee Argus Leader. #30063

JENSEN, Chief Justice

[¶1.] Following the completion of the State’s criminal investigation involving

T. Denny Sanford, also known as Implicated Individual, 1 the circuit court entered

an order to unseal the search warrant affidavits related to the investigation.

Sanford appeals, challenging the denial of his request to inspect and participate in

redacting the affidavits before the circuit court unseals them. We affirm.

Background

[¶2.] This is the second appeal by Sanford challenging the unsealing of a

search warrant file containing five separate search warrants, returns of the

warrants, inventories, and affidavits in an investigation involving Sanford. See In

re an Appeal by an Implicated Individual, 2021 S.D. 61, 966 N.W.2d 578

(Implicated Individual I). In Implicated Individual I, the circuit court had initially

sealed the entire search warrant file based upon law enforcement’s representation

that disclosure would impede the then-ongoing investigation. A ProPublica reporter

requested the documents in the sealed file, prompting the circuit court to review the

scope of its authority to seal the entirety of the search warrant file. ProPublica and

intervenor Argus Leader (Press, collectively) submitted a joint brief to the circuit

court arguing for the file to be unsealed. At the time, the State resisted unsealing

the file, raising concerns that doing so would interfere with the investigation.

1. During the proceedings involved in the first appeal in In re an Appeal by an Implicated Individual, 2021 S.D. 61, 966 N.W.2d 578, T. Denny Sanford was referred to as Implicated Individual because his identity was not a matter of public record. The warrants were unsealed following our decision, and his identity is now a matter of public record.

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Sanford also resisted the request, arguing that the release would impact his privacy

and reputation.

[¶3.] Relying upon SDCL 23A-35-4.1, the circuit court issued amended

orders providing that it was not authorized to seal the contents of the warrants,

return of the warrants, or the inventories. The court ordered such “documents shall

be unsealed and become publicly accessible court records.” The court concluded

pursuant to SDCL 23A-35-4.1 that the affidavits in support of the five search

warrants would remain sealed, but “[f]ollowing termination of the investigation or

filing of an indictment, the document’s contents will [be] unsealed and available to

public inspection or disclosure as a publicly accessible court record.” Sanford and

the State appealed the orders, and the circuit court stayed its ruling pending

appeal.

[¶4.] On appeal to this Court, Sanford argued that rules governing access to

court records found in SDCL chapter 15-15A, promulgated by the South Dakota

Supreme Court, conflicted with statutes enacted by the Legislature and must

prevail because of the judiciary’s inherent authority over its records. Implicated

Individual I, 2021 S.D. 61, ¶ 19, 966 N.W.2d at 584. We interpreted the plain

language of SDCL 23A-35-4.1 to permit a circuit court to “seal the contents of an

affidavit in support of a search warrant upon a showing of reasonable cause, but

only until the investigation is terminated or an indictment or information is filed.”

Id. ¶ 18, 966 N.W.2d at 583. We further observed that “[t]he statute’s text is

equally clear in its command that the court ‘may not prohibit’ the public disclosure

of other specific records, namely, the contents of the warrant, the return of the

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warrant, and the inventory. Nor may the court prohibit public disclosure of the fact

that a search warrant affidavit has been filed.” Id.

[¶5.] We emphasized that “a court’s discretion to ‘prohibit public access to

information in a court record’” as set forth in SDCL 15-15A-13 is limited by the

existence of “sufficient grounds to prohibit access according to applicable

constitutional, statutory and common law.” Id. ¶ 21, 966 N.W.2d at 584 (quoting

SDCL 15-15A-13). 2 We further noted, under SDCL 15-15A-8, that certain

personally identifying information within court records must be redacted as a

matter of course. 3 Id. ¶ 24, 966 N.W.2d at 585. While in Implicated Individual I

2. SDCL 15-15A-13 provides:

A request to prohibit public access to information in a court record may be made by any party to a case, the individual about whom information is present in the court record, or on the court’s own motion. Notice of the request must be provided to all parties in the case and the court may order notice be provided to others with an interest in the matter. The court shall hear any objections from other interested parties to the request to prohibit public access to information in the court record. The court must decide whether there are sufficient grounds to prohibit access according to applicable constitutional, statutory and common law. In deciding this the court should consider the purpose of this rule as set forth in § 15-15A-1. In restricting access, the court will use the least restrictive means that will achieve the purposes of this access rule and the needs of the requestor.

3. SDCL 15-15A-8 provides for automatic redaction of the following:

(1) Social security numbers, employer or taxpayer identification numbers, and financial or medical account numbers of an individual. (2) Financial documents such as income tax returns, W-2’s and schedules, wage stubs, credit card statements, financial (continued . . .) -3- #30063

there was “no redaction question before us[,]” we stated that “[w]e perceive no

tension between our rules allowing for the limited redaction of this information to

protect individual privacy interests and SDCL 23A-35-4.1’s requirement to allow

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Related

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Bluebook (online)
989 N.W.2d 517, 2023 S.D. 16, Counsel Stack Legal Research, https://law.counselstack.com/opinion/matter-of-implicated-individual-sd-2023.