State v. McReynolds

951 N.W.2d 809, 2020 S.D. 65
CourtSouth Dakota Supreme Court
DecidedNovember 24, 2020
Docket29207
StatusPublished
Cited by7 cases

This text of 951 N.W.2d 809 (State v. McReynolds) 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. McReynolds, 951 N.W.2d 809, 2020 S.D. 65 (S.D. 2020).

Opinion

#29207-a-SRJ 2020 S.D. 65

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

STATE OF SOUTH DAKOTA, Plaintiff and Appellee,

v.

JOSEPHINE RAE MCREYNOLDS, Defendant and Appellant.

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

THE HONORABLE SUSAN M. SABERS Judge

JASON R. RAVNSBORG Attorney General

BRENT KEMPEMA Assistant Attorney General Pierre, South Dakota Attorneys for plaintiff and appellee.

MARK KADI of Minnehaha County Office of the Public Advocate Sioux Falls, South Dakota Attorneys for defendant and appellant.

CONSIDERED ON BRIEFS AUGUST 24, 2020 OPINION FILED 11/24/20 #29207

JENSEN, Justice

[¶1.] A jury convicted Josephine Rae McReynolds of simple assault on a law

enforcement officer. McReynolds appeals, arguing that the circuit court erred by

denying her motion for a judgment of acquittal and instructing the jury on the

legality of the initial encounter between McReynolds and law enforcement.

McReynolds also argues that the circuit court violated her confrontation rights

under the Sixth Amendment during the subsequent habitual offender trial by

admitting evidence of McReynolds’s prior felony conviction without providing her an

opportunity to cross-examine the custodian of the record. We affirm.

Facts and Procedural History

[¶2.] On September 14, 2018, at approximately 4:00 a.m., Sioux Falls Police

Sergeant Martin Hoffman encountered a vehicle stopped in a turning lane on

Minnesota Avenue with its hazard lights on. The vehicle was unoccupied; however,

Sergeant Hoffman noticed an individual, later identified as McReynolds, walking

away from the vehicle. Hoffman asked another officer, Logan Watson, to contact

the individual while Hoffman investigated the vehicle.

[¶3.] Hoffman observed a label with the name “Josephine Rae McReynolds”

inside the vehicle in plain view. Simultaneously, Officer Watson spoke with

McReynolds who denied any association with the vehicle and claimed she had seen

someone else associated with the vehicle. McReynolds also began recording the

encounter with Watson. McReynolds then continued to walk further down the

sidewalk.

[¶4.] Hoffman advised Watson of the name he found that was associated

with the vehicle. Watson returned to her patrol vehicle, ran the name in the law -1- #29207

enforcement database, and discovered McReynolds had an outstanding arrest

warrant for failure to appear. Watson identified McReynolds as the person she had

just encountered from a photograph in the database.

[¶5.] After Watson identified McReynolds, Watson approached her a second

time. A third officer, Scott Seiner, also arrived at the scene to assist. McReynolds

began recording the officers with her cell phone and began walking away from the

officers. Officer Seiner commanded her to stop.

[¶6.] Instead, McReynolds ran, and Watson and Seiner gave chase. As

Watson reached McReynolds, McReynolds turned around swinging her right hand

toward Watson’s head. McReynolds was holding her cell phone in her right hand

and struck Watson in the back of the head with the device. Watson stated that as

McReynolds turned, she swung her right hand downward in a “hammer motion.”

Seiner observed McReynolds swinging her right hand in a similar downward motion

as she turned towards Watson. McReynolds was taken to the ground and placed in

custody. Watson received a laceration that required medical attention.

[¶7.] McReynolds was charged with eight counts, including four alternative

counts of simple assault against a law enforcement officer in violation of SDCL 22-

18-1.05. Count two, the charge on which she was ultimately convicted, alleged that

McReynolds committed simple assault under SDCL 22-18-1(2) by “recklessly

caus[ing] bodily injury” to Watson. 1 The State also filed a part II information under

1. In addition to Count 2, the State alleged alternative counts for simple assault against a law enforcement officer under subsections (1), (4), and (5) of SDCL 22-18-1. The indictment also included misdemeanor offenses for obstruction of an officer and drug-related offenses. -2- #29207

the habitual offender statute SDCL 22-7-7, alleging that McReynolds had

previously been convicted of a felony.

[¶8.] Prior to trial, McReynolds filed a motion in limine requesting the

circuit court to exclude evidence of the outstanding arrest warrant. The court

granted McReynolds’s motion and cautioned that McReynolds would “open the door”

to this evidence by suggesting that law enforcement did not have a basis to confront

or stop McReynolds. At trial, Watson testified that she identified McReynolds as

the person associated with the vehicle, without referencing the warrant. Following

McReynolds’s cross-examination of Watson, the circuit court denied the State’s

request to introduce McReynolds’s failure to appear warrant, concluding that

defense counsel had not “opened the door” for this evidence during cross-

examination.

[¶9.] At the conclusion of the evidence, the State proposed instruction 16:

At the time of this incident, the police officers lawfully came into contact with the defendant and the legality of that contact is not in dispute.

The circuit court gave the instruction over McReynolds’s objection. The court also

denied McReynolds’s motion for a judgment of acquittal. The jury returned a

verdict finding McReynolds guilty of one count of simple assault against a law

enforcement officer under SDCL 22-18-1(2) and one count of obstruction. 2

[¶10.] A court trial was held on the part II habitual offender information on

July 10, 2019, that alleged McReynolds had previously been convicted of a simple

2. The State dismissed the drug-related charges and the jury acquitted McReynolds on the three alternative counts of simple assault and the other count of obstruction. -3- #29207

assault against a law enforcement officer in Codington County. A jailer from

Codington County testified that he fingerprinted McReynolds on July 2, 2013, when

she was arrested for simple assault against a law enforcement officer. A

Minnehaha County jailer testified that he fingerprinted McReynolds when she was

arrested for the instant offense of simple assault against a law enforcement officer

on September 14, 2018. An analyst from the South Dakota Forensic Laboratory

identified McReynolds as the individual from whom both sets of fingerprints were

taken. Over McReynolds’s objection, the circuit court received a certified judgment

of conviction from Codington County showing that McReynolds had previously been

convicted of simple assault against a law enforcement officer on October 23, 2013.

The circuit court sustained the habitual offender information, finding that

McReynolds had a prior felony conviction from Codington County. On November 1,

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Cite This Page — Counsel Stack

Bluebook (online)
951 N.W.2d 809, 2020 S.D. 65, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mcreynolds-sd-2020.