The South Dakota Supreme Court issued a decision Tuesday reversing a circuit court's order that would have allowed expert testimony on false confessions in a high-profile murder case. The court ruled in *State v. Huante*, reversing the Seventh Judicial Circuit Court's denial of the State's request to exclude testimony from Dr. Stephen Manlove, an expert witness on false confessions.
Timothy Huante faces first-degree murder charges in connection with the fatal shooting of Dallas Quick Bear at Teddy's, a Rapid City bar, shortly after midnight on February 20, 2022. Police officers responded quickly to the scene and found Quick Bear mortally wounded from what appeared to be a gunshot wound.
The case centers on statements Huante made to law enforcement officers during the investigation. According to court documents, Huante confessed to killing Quick Bear during an interview with police. However, Huante's defense team later disclosed Dr. Stephen Manlove as an expert witness who would testify about false confessions, suggesting that Huante's statements may not be reliable.
The procedural history of the case reveals a complex legal battle over the admissibility of expert testimony. The circuit court, presided over by Judge Matthew M. Brown in Pennington County, initially denied the State's request to exclude Dr. Manlove's testimony. However, the court imposed what are described as "significant restrictions" on the expert's testimony, though the specific nature of these limitations was not detailed in the available court records.
Importantly, Huante did not challenge these restrictions on appeal, suggesting his legal team was satisfied with the circuit court's compromise that would have allowed limited expert testimony on false confessions. The State, however, was not satisfied with this outcome and successfully petitioned the South Dakota Supreme Court for an intermediate appeal.
The South Dakota Supreme Court granted the State's petition for intermediate appeal, which allowed the case to bypass the typical appellate process and go directly to the state's highest court. This procedural move indicates the significance of the legal issues at stake, particularly regarding the standards for admitting expert testimony on psychological topics in criminal cases.
After hearing oral arguments on March 26, 2025, the case was reassigned on September 4, 2025, before Justice Salter issued the court's opinion on February 4, 2026. Justice Salter wrote the opinion on reassignment, though the reasons for the reassignment were not specified in the available documentation.
The court's decision to reverse the circuit court's order represents a victory for the prosecution, led by Attorney General Marty J. Jackley and Assistant Attorney General Erin E. Handke. The State had argued that Dr. Manlove's expert testimony on false confessions should be excluded entirely, rather than merely restricted.
Huante's defense team, consisting of Gregory Sperlich, Angela Colbath, and Kyle Beauchamp from the Colbath & Sperlich Law Office in Rapid City, had sought to introduce expert testimony that could have cast doubt on the reliability of their client's confession. Expert testimony on false confessions has become increasingly common in criminal defense strategies, particularly in cases where defendants have made incriminating statements to law enforcement.
The legal issues surrounding false confession expert testimony often involve complex questions about the reliability of confessions, the psychological factors that can lead to false admissions of guilt, and the standards courts should apply when determining whether such expert testimony is admissible. These cases frequently require courts to balance the probative value of expert testimony against potential prejudice or confusion it might cause to juries.
The Supreme Court's reversal means that Dr. Manlove will not be permitted to testify about false confessions in Huante's trial, potentially strengthening the State's case against the defendant. Without expert testimony to challenge the reliability of his confession, prosecutors may have an easier path to conviction on the first-degree murder charge.
The case now returns to the circuit court level, where proceedings in the underlying murder case will continue without the expert testimony on false confessions. The timing of the trial and other procedural matters will be determined by the circuit court as the case moves forward.
This decision could have broader implications for how South Dakota courts handle expert testimony on psychological topics in criminal cases. The ruling may influence future cases where defendants seek to introduce expert testimony to challenge the reliability of confessions or other evidence involving psychological factors.
The legal proceedings have stretched over nearly four years since Quick Bear's death in February 2022, highlighting the complex nature of first-degree murder prosecutions and the various legal challenges that can arise during the pretrial phase of such serious criminal cases.