Anyone who watches Dateline is acquainted with the phenomenon of false confessions. Police are permitted to misstate existing facts and even lie about non-existent evidence to persuade a suspect into a confession – even if they didn’t do it. In situations where DNA evidence has been used for exoneration, it has been shown that 25% of all wrongful convictions were premised, in part, on false confessions. 

Dallas Quick Bear was shot and killed at a Bar in Rapid City on February 20, 2022. Timothy Huante was also at the Bar that night. Afterward, Huante twice visited with the police about events, and repeatedly denied involvement with the shooting. At the request of the police, Huante met with the police a third time and voluntarily submitted to a polygraph examination. After the examination, police told him he had failed the polygraph. Huante said he was unable to clearly remember the events of that night, that he was intoxicated, but he continued to deny involvement. Police then told Huante, “We know a lot more about this than we’ve told you” and “We know what you did.” The interrogation evolved as follows:

Huante: I didn’t shoot him. I didn’t shoot him. I don’t think I shot him. Did I shoot him?

Police: The polygraph told us that you know you shot him.

Huante: I f***ing shot him.

Defense Counsel located Dr. Stephen Manlove, forensic psychiatrist knowledgeable on the topic of false confessions, and planned to use him in fending off the confession. The trial judge, Honorable Matthew Brown, ruled that the jury would be allowed to hear the Dr. Manlove’s testimony about how false confessions arise, including when the confession aligns with a narrative provided by the police during interrogation – especially when the police indicate that they have more evidence than actually exists.

On appeal, a divided South Dakota Supreme Court ruled that Judge Brown had erred in allowing Dr. Manlove’s testimony, creating a significant blow to the defense strategy.  Its decision was handed down last Thursday in State v Huante (2026 S.D. 6, 2/5/2026). 

This is the first time the Court has addressed the propriety of allowing an expert to testify about false confessions. Although the majority decision stated, “the existence of false confessions [is] grave and discomfiting,” it also held that the testimony did not sufficiently meet South Dakota’s existing criteria for expert testimony.

Supreme Court Justice Myren dissented, expressing the view that the trial judge, who was more familiar with the facts, should be given greater deference. In particular, Justice Myren observed that trial judge correctly determined that Dr. Manlove’s testimony was both relevant and reliable, which are the established legal standards for admitting expert testimony.  

Mr. Huante is charged with the most serious crime on the books – First Degree Murder. If Dr. Manlove were permitted to present testimony concerning false confessions, it would not be a “get out of jail” free card. Rather, the State would still be able to introduce Mr. Huante’s confession into evidence, and it would be up to the jury to decide whether the confession was reliable or believable.

This writer believes that Judge Brown and Justice Myren are correct on this one.

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