## Facts

- Trent Danielson worked as a mechanic and painter for Rocket Lube and was fired after the business accused him of stealing parts and failing to turn over checks received for work performed on a customer’s vehicles.
- Danielson was indicted for grand theft based on the theory that checks paid by the customer for repair work belonged to Rocket Lube as the employer.
- At the grand-theft trial, Danielson testified that he had a private arrangement with the customer and that the checks belonged to him; he also testified that he had performed specific repair work, including replacing parts inside the transmission of the customer’s 1950 Studebaker pickup.
- A jury acquitted Danielson of grand theft.
- Danielson was later indicted for perjury during a felony trial based on the allegation that his transmission-repair testimony at the grand-theft trial was false.
- At the perjury trial, the State presented testimony and used transmission parts as physical evidence to support falsity; a jury convicted Danielson of perjury.

## Issues

1. Whether the evidence was sufficient to prove beyond a reasonable doubt that Danielson intentionally made a materially false statement under oath.
2. Whether the trial court abused its discretion by denying Danielson’s request for a court-appointed private investigator.
3. Whether the trial court abused its discretion by admitting used transmission parts into evidence and by rejecting claims that the State’s handling of the parts required relief for destruction or spoliation of evidence.

## Decision

- The Supreme Court of South Dakota affirmed the perjury conviction.
- The court held that a rational jury could find Danielson’s challenged testimony materially false and intentionally made.
- The court held the trial court did not abuse its discretion in denying a court-appointed private investigator.
- The court held the trial court did not abuse its discretion in admitting the used transmission parts and did not err in rejecting the destruction-of-evidence claim.

## Legal Principles

- A statement is material for perjury purposes if it has a natural tendency to influence, or is capable of influencing, the tribunal’s decision; materiality may include testimony affecting credibility or supporting a defense theory, not only testimony tied to elements of the underlying charge.
- Intentional falsity for perjury may be proved by circumstantial evidence permitting a jury to infer the defendant knowingly testified falsely to support a defense in prior proceedings.
- Sufficiency review asks whether any rational trier of fact could find the essential elements beyond a reasonable doubt when viewing the evidence in favor of the verdict.
- Decisions on court-funded investigative assistance and evidentiary rulings are reviewed for abuse of discretion; relief for lost or altered evidence generally requires a showing that the defendant was denied a fair trial, including (when asserted as a due process violation) proof of bad faith destruction of materially exculpatory evidence.

## Conclusion

The court upheld Danielson’s perjury conviction because his disputed repair testimony could influence the earlier jury’s assessment of his claim-of-right defense and credibility, the record supported findings of falsity and intentional deception, and the trial court’s denial of investigative funding and admission of the transmission parts fell within its discretionary authority without a showing of bad faith or unfairness.


State v. Danielson, 814 N.W.2d 401 (S.D. 2012)