PIERRE, S.D. (South Dakota Searchlight) – The South Dakota Supreme Court ruled this week that a father doesn’t have a right to obtain investigation records he wanted about his son’s death.
Ryan Pyle, age 37, went missing in August 2020, and his remains were found in November of that year near the Snake Creek Recreation Area in South Dakota, near the city of Platte. Law enforcement believed he died of hypothermia. His father, Brian Pyle, believed the death may have involved foul play.
Brian Pyle asked a lower court to force the release of reports and records from the investigation into his son’s death. The lower court said no. The South Dakota Supreme Court affirmed that decision.
“The State had no duty to disclose criminal investigative information, nor did Pyle have a clear right to access such information,” wrote the court.
Pyle’s argument for access included pointing to Marsy’s Law, the South Dakota constitutional amendment passed by voters in 2016 that establishes a formal bill of rights for crime victims. But the court said the record had not proven that a crime occurred, and that Brian “is not a ‘victim,’ as the term is defined under Marsy’s Law, and therefore Marsy’s Law is not applicable.”
Even if Marsy’s Law applied, wrote the court, “none of the nineteen enumerated rights in Marsy’s Law direct or compel the State to disclose investigative reports or records.”
South Dakota law also specifically exempts law-enforcement investigation records from public disclosure requirements.
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