State v. Belt

2024 S.D. 82
CourtSouth Dakota Supreme Court
DecidedDecember 18, 2024
Docket30445
StatusPublished
Cited by5 cases

This text of 2024 S.D. 82 (State v. Belt) 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
State v. Belt, 2024 S.D. 82 (S.D. 2024).

Opinion

#30445-a-MES 2024 S.D. 82

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

STATE OF SOUTH DAKOTA, Plaintiff and Appellee,

v.

WILLIAM CHARLES BELT, Defendant and Appellant.

APPEAL FROM THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT PENNINGTON COUNTY, SOUTH DAKOTA

THE HONORABLE MATTHEW M. BROWN Judge

ELIZABETH REGALADO of Office of the Public Defender for Pennington County Rapid City, South Dakota Attorneys for defendant and appellant.

MARTY J. JACKLEY Attorney General

JOHN M. STROHMAN Assistant Attorney General Pierre, South Dakota Attorneys for plaintiff and appellee.

CONSIDERED ON BRIEFS SEPTEMBER 30, 2024 OPINION FILED 12/18/24 #30445

SALTER, Justice

[¶1.] Following a jury trial, William Belt was convicted of sexual contact

with a person incapable of consenting. In this appeal, he challenges the circuit

court’s decision to allow expert testimony concerning the presence of inconclusive

male DNA found in samples taken from the victim. He also challenges the court’s

jury instruction that referenced the “interests of society” and the court’s decision to

deny his motion for judgment of acquittal. We affirm.

Factual and Procedural Background

[¶2.] In August 2021, 17-year-old D.L. was living with her mother in a small

Rapid City apartment, which was included among a number of similar units

converted from their previous use as motel rooms. They were neighbors with Belt

and his wife who lived in a nearby apartment, though the two families did not know

each other.

[¶3.] At some point spanning the evening of August 16 and the early

morning hours of August 17, D.L.’s mother was detained and held overnight in a

sobering facility. Alone and upset, D.L. began drinking vodka and became highly

intoxicated. The events giving rise to this case occurred during the approximate

time period of 10:00 a.m. to 11:30 a.m. on August 17.

[¶4.] Based upon surveillance video obtained from the apartment’s landlord,

D.L. visited the apartment of her neighbor, William Belt, two times: once at

approximately 10:19 a.m. for about one minute; and a second, longer visit at

approximately 10:42 a.m. that lasted approximately 51 minutes.

-1- #30445

[¶5.] After leaving Belt’s apartment for the second time, police officers

determined that D.L. approached a different neighbor and claimed that Belt had

raped her. However, the neighbor knew Belt and told D.L. she did not believe her.

D.L. returned to her own apartment where she called 911.

[¶6.] Officers responded at approximately 11:48 a.m. and found D.L. sitting

on the floor of her apartment crying. The responding officers described her as very

intoxicated, and subsequent testing and extrapolation placed her blood alcohol

content at between .243% and .258%. D.L. told the officers that Belt tried to put his

“thingy” inside her, but she kept telling him no. She was then taken to the hospital

to complete a sexual assault response team (SART) kit.

[¶7.] While at the hospital, D.L. provided investigators and the sexual

assault nurse examiner (SANE) two different times for the assault. First, she told

them that the incident occurred between 2:00 p.m. and 4:00 p.m. the previous day,

August 16. But she also related a different time frame which began around 3:00

a.m. on August 17 after her mother was taken to the sobering facility. D.L. told

investigators she was unable to sleep and went outside to smoke a cigarette. She

said that while she was outside, a man approached her and “lured” her back to his

apartment, where he sexually assaulted her while his wife was present. D.L. also

informed the SANE that no penetration occurred, but she reported Belt attempted

penetration with his fingers.

[¶8.] Belt agreed to be interviewed by law enforcement officers without an

attorney present, and he submitted to forensic testing of his person. Officers

described him as “very cooperative” during this process. Belt told them that D.L.

-2- #30445

had come to his apartment the morning of August 17 before his wife, Betty, left for

work and asked them to sign a petition concerning some neighbor children; they

declined, and D.L. left. Belt stated that after Betty departed for work, D.L. came

back to his apartment and demanded he give her money, threatening to tell people

he had raped her if he did not comply. Belt stated that he grabbed her by the arm

and ushered her out of his apartment.

[¶9.] The day after the incident, Belt called the police and explained that his

landlord had video surveillance evidence that “would exonerate him.” Belt sought

immediate action because he informed police that the recording would soon be

overwritten with new recorded footage. A police officer responded and watched

footage of the first minute-long visit. After that, however, the officer remotely

accessed a written report concerning the incident from his patrol vehicle and

learned that the sequence of reported events included more than the minute-long

visit. The officer returned and continued to watch the surveillance footage until he

saw evidence of D.L.’s subsequent 51-minute-long visit to Belt’s apartment.

[¶10.] Forensic examiners tested DNA swabs taken from both D.L. and Belt.

Male DNA was not detected in D.L.’s vaginal or cervical swabs. Male DNA was

found on D.L.’s anal, perineal, oral, mons pubis, and fingernail scraping swabs, but

the amount of DNA was insufficient to establish a profile. Belt’s DNA was present

on samples taken from both sides of D.L.’s neck, and D.L.’s DNA was found on

samples taken from Belt’s hands. Perhaps most notable, examiners found the

presence of D.L.’s DNA on penile swabs taken from Belt.

-3- #30445

[¶11.] On September 28, 2022, over a year after the August 2021 incident

was reported, a Pennington County grand jury returned a three-count indictment

charging Belt with second-degree rape in violation of SDCL 22-22-1(2) or, in the

alternative, third-degree rape in violation of SDCL 22-22-1(4). Count 3 of the

indictment charged Belt with sexual contact with a person incapable of consenting

in violation of SDCL 22-22-7.2.

[¶12.] Before trial, Belt moved in limine to exclude expert testimony or

references to the DNA testing that revealed the presence of male DNA but were

otherwise insufficient to identify the contributor. Belt argued that since the

samples were inconclusive, there was a high probability of unfair prejudice or

confusion because the jury was likely to attribute the unidentified male DNA

results to him, especially if the State were allowed to make such an argument.

[¶13.] The State, however, maintained that it was permitted to argue that

the male DNA could belong to Belt, asserting that the probative force of the

evidence outweighed any potential for unfair prejudice. The State admitted that it

would not argue that the inconclusive DNA was, in fact, Belt’s—just that it could be

his. The circuit court denied Belt’s motion, holding that the probative value of the

testimony outweighed any prejudicial effect.

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Cite This Page — Counsel Stack

Bluebook (online)
2024 S.D. 82, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-belt-sd-2024.