State v. Quist, 2018 SD 30.  Defendant was at a bar in Aberdeen and drinking with his “self-described” best friend.  Defendant and his friend got into an argument about loaned money.  Surveillance video recorded Defendant leaving the bar to smoke a cigarette, with Defendant’s friend also leaving the bar and walking away from Defendant.  While the friend’s back was turned, Defendant jogged up behind him and struck him.  The friend turned around, but was struck again by the Defendant, which knocked the friend to the ground.  Defendant then proceeded to kick the friend multiple times while he was on the ground.

Law enforcement arrived; bar employees identified Defendant; and Defendant made various admissions about his physical contact to his friend.  Ultimately, the friend died as a result of the injuries suffered that night from the Defendant, who was charged with second-degree murder.  Defendant was found guilty and appealed various issues.

The Supreme Court of South Dakota first held that the State’s return of the friend’s body to his family did not deprive the Defendant of due process, that Defendant failed to demonstrate he was deprived of exculpatory evidence, and that a dismissal was not warranted.  Secondly, the Court found that the totality of the evidence in the case was clearly sufficient to support Defendant’s conviction given the surveillance video directly showing Defendant brutally killed his friend without provocation.  Lastly, the Court found that the admission of autopsy photos was allowed as they were relevant to proving that Defendant’s “blows were imminently dangerous to [the friend], evincing a depraved mind, without regard for human life.”  As such, the jury’s conviction of the Defendant was affirmed.