State of South Dakota, Plaintiff and Appellee v. Jerry A. Lamont, Defendant and Appellant

Summary

The court held that the trial court improperly barred Lamont from presenting evidence concerning the decedent's blood alcohol level to challenge proximate cause, requiring reversal on that issue and a new trial. It upheld the warrantless second entry into Lamont's motel room because the officers had probable cause and objectively reasonable exigent circumstances involving a serious vehicular-homicide investigation and potentially dissipating alcohol evidence. It also held that a second blood draw taken one hour after the first was reasonable under the totality of the circumstances. Justice Amundson, dissenting on Issues 2 and 3, would have suppressed the evidence from the warrantless entry and the second blood draw, while Justice Sabers joined that dissent subject to a reservation that later circumstances could justify a second blood test.