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Attorney General Jackley Commends SD Supreme Court Ruling Upholding Law Enforcement Decision Not to Release Confidential Investigation Records

FOR IMMEDIATE RELEASE: Thursday, Oct. 1, 2026

Contact: Tony Mangan, Communications Director, 605-773-6878 

PIERRE, S.D. – South Dakota Attorney General Marty Jackley commends the South Dakota Supreme Court for its ruling that certain law enforcement investigative records are not open to the public due to state law.

Brian Pyle had requested all reports and information regarding the investigation of the disappearance and death of Pyle’s son, Ryan, who was reported missing in August 2020. The South Dakota Division of Criminal Investigation (DCI), the Charles Mix CountySheriff’s Office, and the Gregory County Sheriff’s Office had investigated. Ryan’s remains were found in November 2022 near the Sand Creek Recreation Area near Platte. Ryan’s death was ruled to be of natural causes.  Brian Pyle had been interviewed during the investigation and had been informed that Ryan had died of natural causes.

State attorneys had argued at a Circuit Court hearing on Pyle’s request that the law enforcement’s investigative records are confidential criminal justice information that is statutorily exempt from disclosure. The State argued that Pyle also was not a victim in this case because no crime had been committed, thus Marsy’s Law did not apply.

The Supreme Court agreed with the circuit court’s decision, ruling that there was no evidence presented that a crime had been committed and Marsy’s Law did not apply.  The Supreme Court also ruled that even if Marsy’s Law did apply, state law deems the requested records as confidential and not open to the public.

“South Dakota law enforcement agencies do outstanding investigative work which is wide-ranging, and the information discovered can be sensitive,” said Attorney General Jackley. “I appreciate the Supreme Court’s understanding that not all information can be released to the public due to state law.”

The Attorney General’s Office represented the State at the appeal. The opinion can be found here: https://ujs.sd.gov/media/tqenfnpv/31092.pdf

                                                                             -30-

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