State v. Cummings
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The Supreme Court reversed the decision of the circuit court granting Defendant's motion to suppress statements he made to a state officer on the grounds that the officer lacked authority to investigate crimes in Indian country, holding that the officer did not violate any jurisdictional principles by entering Indian country to investigate crimes that occurred outside Indian country.
When Defendant spoke with agents from the South Dakota Division of Criminal Investigation and the Bureau of Indian Affairs at his home located on Indian trust land concerning property crimes that had occurred outside Indian country he produced evidence implicating him a burglary in Bennett County. Defendant was charged in state court. The circuit court suppressed Defendant's statements, concluding that the agents did not have authority to investigate state criminal offenses in Indian country. The Supreme Court reversed, holding (1) Defendant failed to show that the agents lacked authority to investigate state offenses while in Indian country or that the agents' actions infringed upon tribal sovereignty; and (2) Defendant failed to show a Fourth Amendment violation.
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