State v. Lee

2017 SD 28, 896 N.W.2d 281, 2017 WL 2178445, 2017 S.D. LEXIS 60
CourtSouth Dakota Supreme Court
DecidedMay 17, 2017
Docket27984
StatusPublished

This text of 2017 SD 28 (State v. Lee) 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. Lee, 2017 SD 28, 896 N.W.2d 281, 2017 WL 2178445, 2017 S.D. LEXIS 60 (S.D. 2017).

Opinion

SEVERSON, Justice

[¶1.] An asset protection associate at a Walmart placed Ashley Lee under citizen’s arrest for theft. The associate contacted law enforcement, who took Lee into custody and searched her purse, finding a pipe with methamphetamine residue. Lee moved to suppress all evidence from the search, alleging that law enforcement had no authority to arrest her and thus the search was illegal. The circuit court agreed with Lee and suppressed all evidence obtained from the search. On intermediate appeal, the State alleges that the search was a proper search incident to an arrest. We reverse the circuit court’s order granting Lee’s motion to suppress evidence.

Background

[¶2.] On May 16, 2015, Lee was shopping at a Walmart in Rapid City when an asset protection associate, Aaron Miller, noticed her concealing items in her purse. She paid for other items at the store, but failed to pay for those that she had placed in her purse. After she passed all points of sale, Miller apprehended her. He recovered the items stolen (totaling a value of $36.63), reported the incident to the police, and detained her until an officer arrived. Miller described the incident in a “Citizen’s Arrest Report.” Officer Duane Baker with the Rapid City Police Department responded to the report of the theft. He performed a warrantless search of her purse and found a glass pipe. Residue on the pipe tested positive for methamphetamine.

[¶3.] A complaint was filed on May 20, 2015, charging Lee with petty theft and possession of a controlled substance. On July 8, 2015, she was charged by an information with possession of a controlled substance. A part II information alleged that she was convicted of two felonies in 2014. Lee moved to suppress the evidence obtained as a result of the search, claiming that law enforcement arrested her without a warrant for a Class 2 misdemeanor committed outside an officer’s presence, in violation of SDCL 23A-3-2. Therefore, according to Lee, there was no authority to search her incident to an arrest.

[¶4.] On July 28, 2016, the circuit court filed findings of fact and conclusions of law directing suppression of the evidence. It concluded that a citizen’s arrest “merely permits detention of a suspect until he [or she] may be taken before a magistrate or delivered to the nearest available law enforcement officer. A citizen’s arrest does not entitle a police officer to make a custodial arrest when he otherwise would not have that authority.” The State asserts that the circuit court erred and that law enforcement may validly search, without a warrant, a person incident to a citizen’s arrest.

*283 Analysis

[¶5.] “A motion to suppress for an alleged violation of a constitutionally protected right raises a question of law, requiring de novo review.” State v. Hess, 2004 S.D. 60, ¶ 9, 680 N.W.2d 314, 319 (quoting State v. Herrmann, 2002 S.D. 119, ¶ 9, 652 N.W.2d 725, 728). Pursuant to SDCL 23A-3-3,

Any person may arrest another:

(1) For a public offense, other than a petty offense, committed or attempted in his presence; or
(2) For a felony which has been in fact committed although not in his presence, if he has probable cause to believe the person to be arrested committed it.

Similarly, law enforcement may arrest citizens without a warrant pursuant to SDCL 23A-3-2, which provides:

A law enforcement officer may, without a warrant, arrest a person:
(1) For a public offense, other than a petty offense, committed or attempted in his presence; or
(2) Upon probable cause that a felony or Class 1 misdemeanor has been committed and the person arrested committed it, although not in the officer’s presence.

Lee concedes that she is not challenging the validity of her citizen’s arrest under SDCL 23A-3-3. 1 There is also no dispute that petty theft is a Class 2 misdemeanor; that the theft occurred outside Officer Baker’s presence; and therefore Officer Baker did not have authority under SDCL 23A-3-2 to arrest Lee. The only issue is Officer Baker’s authority to take Lee into custody after she had been placed under citizen’s arrest by the Wal-mart associate and to perform a search of her incident to the citizen’s arrest. See State v. Bonrud, 393 N.W.2d 785, 787 (S.D. 1986) (explaining warrantless searches are unconstitutional unless the search falls within a recognized exception to the general rule requiring a search warrant); State v. Smith, 2014 S.D. 50, ¶ 15, 851 N.W.2d 719, 724 (“Search incident to lawful arrest is one of the well-delineated exceptions to the warrant requirement.”).

[¶6.] We have previously upheld a search of a defendant by a sheriff after the defendant was placed under citizen’s arrest. In State v. Bonrud, two men stole a money box from a person “distributing religious pamphlets and putting any money donations he received from their sale” in the box. 393 N.W.2d at 786. A citizen who saw the men grab the box chased the men down and detained them until the sheriff arrived. The sheriff searched the vehicle that defendant was riding in and gathered the money and box from the vehicle. Defendant challenged the validity of the citizen’s arrest and claimed that any evidence seized after the allegedly illegal citizen’s arrest should be suppressed. Id.

[¶7.] We upheld the citizen’s arrest and also addressed the constitutionality of the search. Id. at 787. We cited the United States Supreme Court decision New York v. Belton, which held that “when a policeman has made a lawful custodial arrest of the occupant of an automobile, he may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile.” 453 U.S. 454, 460, 101 S.Ct. 2860, 2864, 69 L.Ed.2d 768 (1981), abrogation recognized by Davis v. United States, 564 U.S. 229, 234, 131 S.Ct. 2419, 2425, 180 L.Ed.2d 285 (2011) (explaining that an *284 automobile search incident to recent occupant’s arrest is constitutional if the arres-tee is within reaching distance of the vehicle during the search or the police have reason to believe that the vehicle contains evidence relevant to the arrest). We noted that “[t]he record [did] not specifically reflect that the sheriff, on his own part arrested [defendant], but it clearly shows that he took him into custody.” Bonrud, 393 N.W.2d at 787. And we determined that Belton applied, holding:

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Related

New York v. Belton
453 U.S. 454 (Supreme Court, 1981)
Robert George Moll v. United States
413 F.2d 1233 (Fifth Circuit, 1969)
State v. Brassfield
2000 SD 110 (South Dakota Supreme Court, 2000)
State v. Herrmann
2002 SD 119 (South Dakota Supreme Court, 2002)
State v. Hess
2004 SD 60 (South Dakota Supreme Court, 2004)
State v. Ludemann
2010 SD 9 (South Dakota Supreme Court, 2010)
State v. Bonrud
393 N.W.2d 785 (South Dakota Supreme Court, 1986)
People v. Bland
884 P.2d 312 (Supreme Court of Colorado, 1994)
State v. Smith
2014 SD 50 (South Dakota Supreme Court, 2014)
Davis v. United States
180 L. Ed. 2d 285 (Supreme Court, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
2017 SD 28, 896 N.W.2d 281, 2017 WL 2178445, 2017 S.D. LEXIS 60, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lee-sd-2017.