State v. Horned Eagle
Annotate this CaseDefendant was indicted with one count of second-degree rape. During his trial, Defendant requested access to summaries written by the prosecutor or by others in the prosecutor’s office documenting the victim’s oral declarations about the alleged rape, claiming that the notes were discoverable under S.D. Codified Laws 23A-13-10(4). The trial court concluded that the prosecutor’s notes were protected attorney work product and did not fall under section 23A-13-10. The jury subsequently found Defendant guilty of rape. The Supreme Court reversed, holding that Defendant was entitled to have notes in the possession of the prosecutor containing summaries of the victim’s prior statements related to the allegations against Defendant produced for an in camera review by the circuit court to determine if those notes contain statements discoverable under section 23A-13-10(4). If the court concludes that the notes contain discoverable statements under section 23A-13-10 that could have affected the outcome of the trial, the court is directed to vacate Defendant’s conviction and order a new trial.
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