State v. Cummings

954 N.W.2d 731, 2021 S.D. 4
CourtSouth Dakota Supreme Court
DecidedJanuary 27, 2021
Docket29010
StatusPublished
Cited by2 cases

This text of 954 N.W.2d 731 (State v. Cummings) 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. Cummings, 954 N.W.2d 731, 2021 S.D. 4 (S.D. 2021).

Opinion

#29010-r-SRJ 2021 S.D. 4

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

STATE OF SOUTH DAKOTA, Plaintiff and Appellant, v.

MORGAN CUMMINGS, Defendant and Appellee.

APPEAL FROM THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT BENNETT COUNTY, SOUTH DAKOTA

THE HONORABLE BOBBI J. RANK Judge

JASON R. RAVNSBORG Attorney General

STACY R. HEGGE Assistant Attorney General Pierre, South Dakota

SARAH E. HARRIS Bennett County State’s Attorney Martin, South Dakota Attorneys for plaintiff and appellant.

TERRY L. PECHOTA Rapid City, South Dakota Attorney for defendant and appellee.

**** ARGUED FEBRUARY 11, 2020 OPINION FILED 01/27/21 #29010

JENSEN, Chief Justice

[¶1.] Agents from the South Dakota Division of Criminal Investigation and

the Bureau of Indian Affairs spoke with Morgan Cummings and his father Charlie

Cummings at their home located on Indian trust land concerning property crimes

that had occurred outside Indian country. 1 Morgan and Charlie agreed to speak

with the officers and produced evidence implicating Morgan in a burglary in

Bennett County. Morgan was later charged in state court. The circuit court

granted Morgan’s motion to suppress statements he made to a state officer,

determining that the officer lacked authority to investigate crimes in Indian

country. We granted the State’s petition for intermediate appeal of the circuit

court’s order suppressing Morgan’s statements. We now reverse the circuit court’s

decision.

Facts and Procedural History

[¶2.] In January 2017, various state law enforcement agencies were

investigating recent burglaries and thefts that had occurred outside Indian country

in Martin, South Dakota. Morgan Cummings was a suspect. Morgan was eighteen

at the time and lived with his father, Charlie Cummings, in Sunrise Housing; which

1. Indian country is defined in 18 U.S.C. § 1151 and includes all land within any Indian reservation, dependent Indian communities, and Indian allotments for which “Indian titles . . . have not been extinguished . . . .” The United States Supreme Court has held “that the test for determining whether land is Indian country does not turn upon whether that land is denominated ‘trust land’ or ‘reservation.’ Rather, we ask whether the area has been ‘validly set apart for the use of the Indians as such, under the superintendence of the Government.’” Oklahoma Tax Comm’n v. Citizen Band Potawatomi Indian Tribe of Oklahoma, 498 U.S. 505, 511, 111 S. Ct. 905, 910, 112 L. Ed. 2d 1112 (1991) (quoting United States v. John, 437 U.S. 634, 648-49, 98 S. Ct. 2541, 2549, 57 L. Ed. 2d 489 (1978)).

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is in Indian country on the east side of Martin. 2 On January 9, 2017, at

approximately 1:15 p.m., Special Agent Rasmussen of the South Dakota Division of

Criminal Investigation (DCI) and Special Agent Hooper of the Bureau of Indian

Affairs (BIA) went to the Cummings’ house to investigate the burglaries and thefts.

DCI Special Agent Patterson was also present, but he did not testify; and there is no

showing that he possessed any federal authority in Indian country.

[¶3.] As a BIA officer, Agent Hooper was authorized to investigate and make

arrests for crimes committed in Indian country and “serve warrants, summonses, or

other orders relating to a crime committed in Indian country . . . .” 25 U.S.C. §

2803. Agent Hooper was also authorized “when requested, [to] assist . . . any

Federal, tribal, State, or local law enforcement agency in the enforcement or

carrying out of the laws or regulations the agency enforces or administers.” Id.

Agents Rasmussen and Hooper were members of the Northern Plains Safe Trails

Drug Enforcement Task Force. Agent Rasmussen was federally deputized to

investigate drug offenses in Indian country pursuant to 21 U.S.C. § 801 et. seq.

[¶4.] Upon approaching the Cummings’ residence, the officers knocked on

the front door. Charlie answered, and the officers identified themselves as drug

task force officers, said they were investigating recent burglaries and thefts that

had occurred outside Indian country, and asked to speak to Morgan. Charlie

2. There was no direct evidence or finding by the circuit court that the Cummings are members of a federally recognized Indian tribe or otherwise qualify as Indians under federal law. On appeal, the State concedes the Cummings’ Indian status, though it acknowledges uncertainty about whether they are members. We assume for the purpose of our analysis that the Cummings are Indians under federal law.

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invited the officers in and woke Morgan. Morgan agreed to follow Agent Rasmussen

out to Rasmussen’s vehicle to talk. The vehicle was unlocked, and Morgan sat in

the passenger seat. He was told that he was free to leave at any time. Morgan and

Agent Rasmussen talked for twenty minutes. During the conversation, Morgan

made certain admissions, including admitting to taking a saddle that the officers

were investigating as stolen. He agreed to show Agent Rasmussen where the

saddle was located in the basement.

[¶5.] While Morgan and Agent Rasmussen were outside, Agent Hooper

discussed the stolen items they were looking for with Charlie and asked for consent

to search the home. Charlie offered to show the officers the items that had been

described. Charlie led Agent Hooper to a saddle and saddle blanket, along with

other items. Those items were placed in a pile in the kitchen. When Morgan and

Agent Rasmussen returned to the house, Agent Rasmussen asked Morgan to show

him where other stolen items were located; and Morgan did so. After all the items

were collected, Charlie and Morgan both signed a consent to search form.

[¶6.] Morgan was indicted for third-degree burglary, grand theft, and

intentional damage to property in state court. He moved to suppress his statements

and the items provided to law enforcement, claiming law enforcement’s actions

violated the Fourth and Fifth Amendments to the United States Constitution.

Specifically, Morgan argued Agent Rasmussen did not have the authority to

question him in Indian country, his statements were involuntary, and the search

was not consensual. Following an evidentiary hearing, the circuit court suppressed

Morgan’s statements relying exclusively on our decisions in State v. Spotted Horse,

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462 N.W.2d 463 (S.D. 1990), and State v. Cummings, 2004 S.D. 56, 679 N.W.2d 484,

to conclude that Agent Rasmussen did not have authority to investigate state

criminal offenses in Indian country. The court refused to suppress the physical

evidence, determining that Agent Hooper had investigative authority within Indian

country as a BIA officer and that Charlie’s decision to voluntarily produce the

physical evidence was an intervening event that removed the taint of Agent

Rasmussen’s interview of Morgan.

[¶7.] The circuit court denied the State’s motion for reconsideration

following a hearing, but the circuit court clarified its ruling by determining that

Morgan’s statements to Agent Rasmussen were voluntary. 3 The State petitioned

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Bluebook (online)
954 N.W.2d 731, 2021 S.D. 4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cummings-sd-2021.