The South Dakota Supreme Court recently ruled against Brian Pyle in a case concerning his request for investigative records related to his son’s death. The court's decision, issued on September 30, 2026, affirms a lower court's ruling that denied Pyle's application for a writ of mandamus. This ruling affects Pyle and potentially other individuals seeking access to similar records under South Dakota law.
The case, Pyle v. S.D. Division of Criminal Investigation, revolves around Pyle's efforts to obtain information about the investigation into the death of his son, Ryan. Ryan was reported missing in August 2020, and his remains were discovered in November 2020 near the Snake Creek Recreation Area in Platte, South Dakota. The court's ruling is significant as it highlights the limitations of access to investigative records under state law.
Brian Pyle filed an application for a writ of mandamus in the circuit court, seeking an order to compel several law enforcement agencies to provide him with reports and records related to his son’s investigation. He claimed that his requests for medical records and police reports had been ignored by the South Dakota Division of Criminal Investigation (DCI) and other state entities involved in the case. Pyle cited Marsy’s Law, which grants certain rights to victims of crimes, as a basis for his request.
The circuit court initially issued a peremptory writ, requiring the respondents to respond to Pyle's application. However, the respondents, which included the State of South Dakota and various law enforcement officials, filed a motion to quash the writ. They argued that Pyle had not provided sufficient grounds for the relief he sought and that he had not exhausted other remedies available under South Dakota law.
During a hearing, the court heard arguments from both sides. The State maintained that the investigation into Ryan's death had concluded, with law enforcement determining that no foul play was involved. They argued that because no crime had been committed, Pyle could not be considered a victim under Marsy’s Law, which defines a victim as someone against whom a crime has been committed.
The circuit court ultimately sided with the State, granting the motion to quash the writ and denying Pyle’s application for a writ of mandamus. The court found that Pyle did not qualify as a victim under Marsy’s Law and that the law does not impose a duty on the State to disclose investigative records. Furthermore, the court noted that South Dakota law exempts certain investigative records from public disclosure, reinforcing the State's position.
The South Dakota Supreme Court, led by Justice Patricia J. DeVaney, affirmed the circuit court's decision. The ruling emphasized that Pyle could not invoke the rights of victims under Marsy’s Law because law enforcement had determined that no crime had occurred in connection with his son’s death. The court stated, "Pyle cannot, therefore, invoke the rights afforded to victims under Marsy’s Law as a basis for his request for mandamus relief."
The court also clarified that even if Pyle had been deemed a victim, Marsy’s Law does not guarantee access to investigative records. The justices pointed out that the law primarily focuses on ensuring victims are informed and allowed to participate in the criminal justice system, rather than compelling the disclosure of investigative information.
This ruling has implications for individuals seeking access to investigative records in South Dakota. It reinforces the notion that access to such records is limited and governed by specific statutes that exempt certain information from public disclosure. The decision may deter others who wish to pursue similar requests without clear evidence of a crime being committed.
In terms of future actions, Pyle may consider appealing the decision to a higher court, although details regarding any potential appeal were not available in the court filing. The case underscores the ongoing legal debate surrounding victims' rights and access to information in criminal investigations.