State v. Richter

2025 S.D. 58
CourtSouth Dakota Supreme Court
DecidedNovember 5, 2025
Docket30804
StatusPublished

This text of 2025 S.D. 58 (State v. Richter) 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. Richter, 2025 S.D. 58 (S.D. 2025).

Opinion

#30804-a-SPM 2025 S.D. 58

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

STATE OF SOUTH DAKOTA, Plaintiff and Appellee,

v.

LARRY GENE RICHTER, Defendant and Appellant.

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

THE HONORABLE JON C. SOGN Judge

NICOLE J. LAUGHLIN Sioux Falls, South Dakota Attorney for defendant and appellant.

MARTY J. JACKLEY Attorney General

ANGELA R. SHUTE Assistant Attorney General Pierre, South Dakota Attorneys for plaintiff and appellee.

ARGUED OCTOBER 8, 2025 OPINION FILED 11/5/25 #30804

MYREN, Justice

[¶1.] Larry Richter was convicted of three counts of sexual contact with a

person incapable of consenting. D.W., the victim of all three counts, is a

developmentally disabled adult. At trial, the circuit court allowed D.W. to testify

while holding a stuffed animal. The circuit court denied Richter’s motions for

judgment of acquittal made at the close of the State’s evidence and at the end of the

trial. Richter appeals these two issues, along with two others that he failed to

preserve for appellate review—one involving the trial testimony of a physician that

evaluated D.W. following his encounters with Richter and the other relating to the

State’s cross-examination of Richter. We affirm.

Factual and Procedural Background

[¶2.] Richter hosted a Fourth of July celebration at his home in Sioux Falls.

Richter provided food, fireworks, and other amenities for his numerous guests. The

festivities began on the third and lasted into the early hours of the fourth.

[¶3.] D.W. and his family are Richter’s neighbors and attended Richter’s

celebration. D.W. was nineteen years old at the time, but is developmentally

disabled, functioning at the intellectual level of a seven-year-old. D.W.’s mother,

Tracy, is his court-appointed guardian and conservator. At the trial, she testified

that D.W. has difficulty learning, that his speech was delayed as a child, that he

does not have a driver’s license, that he cannot live independently, and that he has

difficulty reading and writing.

[¶4.] In the days following the celebration, D.W. reported that Richter had

touched him inappropriately on three occasions. One incident occurred on a four-

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wheeler during the afternoon of July 3. The guests at the party were riding

Richter’s four-wheelers, and D.W. asked if he could go for a ride. Richter let D.W.

drive a four-wheeler while Richter sat behind him. D.W. reported that while he was

driving the four-wheeler, Richter placed one hand around him and the other on

D.W.’s genitals over his clothing. D.W. testified that he asked Richter to stop that

touching, but that Richter refused to do so.

[¶5.] During the second incident, D.W. and Richter were sitting on top of a

covered hot tub in Richter’s backyard talking. D.W. said that Richter touched his

“private parts” over the clothing. D.W. testified that he told Richter to stop, but

that “[h]e kept doing it. I [told] him lots of times to stop, but he kept on doing it.”

Tracy came to check on D.W. around the time of the incident, and Richter removed

his hand when Tracy approached. D.W. explained that he wanted to tell her what

was happening, but he did not because he was scared.

[¶6.] The final incident occurred behind a trailer in Richter’s yard. At

Richter’s request, D.W. met him behind the trailer. D.W. described that incident as

follows:

Q: So tell us what happened when you got behind the trailer? A: We got behind the trailer and - - we got behind the trailer, and he sat down with me on the trailer. And he reached for the ball, but this time instead of on the pants, he went inside my pants, on the ball inside. Q: So did his bare skin touch your bare skin? A: Yes. It did. Q: And did you say anything? A: I told him to stop. Q: What did he say? A: He kept doing it. Q: So when his hand was on your bare skin, was it for just a short period of time or a long period of time? A: Long period of time.

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[¶7.] After D.W. reported these incidents, Tracy recorded a phone call with

Richter during which she confronted him about D.W.’s accusations. During the

phone call, Richter made the following statements:

Richter: That’s when I actually touched him there, and I never even got my hand down his pants and touched his testicles. ... Richter: I did back there two times. Tracy: Okay, you did admit then, you did touch it a couple times. Richter: Yes, back there on the thing. Tracy: On the four-wheeler. Richter: No, not. No, on the four-wheeler on the outside yes. I had my hands around his crotch. ... Richter: I said does this bother you and he says no . . . and I reached my hand down, but that was on the outside. ... Tracy: Behind the trailer is when you put your hand down his pants. Richter: Oh, yeah, that, uh, well I tried, I started reaching down towards him. I was going to[.] ... Richter: I admit to those three things.

After recording the phone call, Tracy contacted law enforcement, shared the

recorded phone call, and explained that D.W. had intellectual disabilities. The

recorded phone call was received into evidence at trial.

[¶8.] A detective referred D.W. to Child’s Voice for an evaluation. Child’s

Voice is a hospital-based advocacy center that evaluates children and

developmentally disabled adults who may be victims of abuse or neglect. Dr. Nancy

Free interviewed D.W. At the trial, Dr. Free testified that “[D.W.] clearly has some

delays[,]” and that “[h]e processes much more slowly than his peers without

disabilities. He has difficulty problem solving as well.” She also explained that

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individuals with developmental disabilities are at an increased vulnerability to

various kinds of abuse.

[¶9.] Richter was indicted for three counts of sexual contact with a person

incapable of consenting. After learning that D.W. intended to testify while holding

a stuffed animal (a monkey named “Ish” that holds a banana), Richter filed a

motion in limine to prohibit D.W. “from having a stuffed animal with him on the

witness stand.” The circuit court reserved ruling on Richter’s motion until the first

morning of trial because it wanted to discuss the issue with D.W. The circuit court

spoke with D.W. outside the presence of the jury, with Richter, his attorney, and the

State’s Attorneys present. D.W. explained that he was nervous about testifying and

that he had the stuffed animal with him “[b]ecause he’s a support to me. Because - -

in case I need calmed down, he keeps me calmed down.” After questioning D.W.,

the circuit court allowed him to testify with the stuffed animal:

Well, under the circumstances, I am going to allow him to have that stuffed animal with him. As [D.W.] said, it helps him remain calm. Helps with nerves when he’s testifying. I am going to find that it’s appropriate for him to be able to have that stuffed animal while he’s testifying. And I do not see that it would present a danger of unfair prejudice to the defendant.

[¶10.] Following the State’s case-in-chief, Richter requested a judgment of

acquittal, arguing the State did not establish “a prima facie case.” The circuit court

denied the motion and denied a renewed motion at the end of the trial. The jury

convicted Richter on all three counts.

[¶11.] Richter appeals, raising four issues for this Court’s review: (1) whether

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Bluebook (online)
2025 S.D. 58, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-richter-sd-2025.