I. Introduction

In State v. Biteler, 2025 S.D. 73, the Supreme Court of South Dakota addressed a modern question arising from technologically mediated criminal-justice supervision: when a defendant manipulates a court‑ordered remote breath-testing device, does the resulting data and photograph constitute a “report” to law enforcement for purposes of the false-reporting statute, SDCL 22‑11‑9(3)?

The case sits at the intersection of traditional criminal statutes and contemporary monitoring technology. The defendant, Amanda Biteler, was required to participate in the State’s 24/7 alcohol monitoring program as a condition of bond on a second‑offense DUI charge. After she was approved for “remote breath” testing, a series of test submissions generated photographs that led law enforcement to suspect someone else was blowing into the device.

Prosecutors charged her not with a 24/7 program violation alone, but with criminal false reporting to authorities under SDCL 22‑11‑9(3). The magistrate court convicted her on one count; the circuit court reversed, holding that a coerced 24/7 breath submission was not a “report.” On further appeal, the Supreme Court reversed the circuit court and reinstated the conviction, providing an authoritative interpretation of “report” under SDCL 22‑11‑9(3) and clarifying how that term applies to automated, technology‑based communications in a compelled supervision context.

The opinion, authored by Justice Myren, and a special concurrence by Justice Salter (joined by Retired Justice Kern), together reinforce a broad, text‑driven interpretation of the false‑reporting statute and emphasize separation‑of‑powers limits on judicial narrowing of clear criminal statutes.

II. Background and Procedural History

A. Underlying DUI Charge and 24/7 Program

In March 2023, Amanda Biteler was arrested and charged in Lincoln County with driving under the influence, second offense. As a condition of her pretrial release, she was ordered to participate in South Dakota’s 24/7 alcohol monitoring program. Initially, she had to appear in person for preliminary breath tests (PBTs).

In September 2023, she was authorized to switch to “remote breath,” a portable PBT unit that allows participants to submit breath samples from any location. The device:

• Has a built‑in camera that takes photographs only when someone blows into the unit.
• Automatically transmits the breath test result and photograph to Alcohol Monitoring Systems, Inc. (AMS).
• Is monitored by law enforcement, which accesses the transmitted data from AMS.

Officer Jamie Smith, who supervised the 24/7 program in Lincoln County, instructed Biteler on:

• How to operate and care for the device, and
• How to position her head so the device could capture a clear image of her face when she blew into it.

B. Suspicious Remote Breath Submissions and Charges

On December 9, 2023, AMS software flagged one of Biteler’s evening submissions as suspect. Reviewing the photograph, Officer Smith noticed:

• The straw visible in the image was malleable, unlike the rigid straws on the official remote breath devices.
• Biteler did not have a straw in her mouth; thus, her breath could not have triggered the camera function.
• There was another person’s face visible behind her right shoulder.

These observations led Officer Smith to suspect that someone else had blown into the device while Biteler merely presented her face to the camera.

After reviewing prior submissions, Officer Smith found five additional instances where he believed the test or photograph had been manipulated. The State charged Biteler with six counts of false reporting to authorities under SDCL 22‑11‑9(3). That subsection criminalizes:

“Mak[ing] a report or intentionally caus[ing] the transmission of a report to law enforcement authorities which furnishes information relating to an offense or other incident within their official concern, knowing that such information is false[.]”

C. Magistrate Court Trial and Conviction

A court trial was held before the magistrate court on June 7, 2024. Officer Smith was the sole witness and described:

• The operation of the remote breath device;
• How test results and photographs are transmitted via AMS; and
• Why the December 9 and other photographs suggested manipulation.

The State argued that each flagged photograph, viewed with the circumstantial evidence, met the elements of SDCL 22‑11‑9(3). The defense contended:

• The false‑reporting statute was not intended for 24/7 program violations;
• Because the data first went to AMS, she had not “filed” a report with law enforcement; and
• Given the coercive nature of the 24/7 condition, her actions were “compliance, not communication,” and thus not a “report.”

As to the December 9 incident, the magistrate court found:

1. The breath sample and accompanying photograph constituted a “report” under SDCL 22‑11‑9(3);
2. Biteler intentionally caused that report to be transmitted to law enforcement;
3. The report related to an incident within law enforcement’s official concern—her compliance with the court‑ordered 24/7 program; and
4. She knew the information was false when she submitted it.

The magistrate court convicted her on the December 9 count and acquitted her on the remaining five counts.

D. Circuit Court Reversal

On appeal, the circuit court reversed the conviction, focusing on whether the breath submission was a “report” under SDCL 22‑11‑9(3). Because “report” is not statutorily defined, the court:

• Treated “report” as a noun; and
• Consulted dictionary definitions, selecting a meaning such as “a formal oral or written presentation of the results of an investigation, research assignment, etc.”

Applying this narrow understanding, the circuit court concluded:

“[A] breathalyzer submission or other bodily substance submission as occurred in this case is not a communication or report for the purposes of the statute. … [Her] conduct was not a specific, intentional, affirmative communication, account, or statement to law enforcement.”

The court acknowledged that she may have violated 24/7 program conditions (with consequences in the DUI case) but held that SDCL 22‑11‑9(3) was not satisfied.

E. Supreme Court Appeal

The State appealed to the Supreme Court of South Dakota, which reviewed the statutory-interpretation question de novo and ultimately reinstated the magistrate court’s judgment of conviction.

III. Summary of the Supreme Court’s Opinion

The Supreme Court held that:

• The term “report” in SDCL 22‑11‑9(3) is not ambiguous and should be read in light of the statute as a whole rather than narrowed by an external dictionary definition.
• A “report” under this statute means any communication that furnishes information relating to an offense or other incident within law enforcement’s official concern.
• The statute is technology- and medium-neutral: it does not limit “report” to formal, written, oral, or voluntary statements, nor to unprompted, unilateral communications.
• By using the remote breath device with knowledge that it would automatically send test results and photographs (via AMS) to law enforcement, and by arranging for another person to blow into the device, Biteler “intentionally caused the transmission of a report” to law enforcement that she knew was false.
• Her participation in the 24/7 program, even if compelled as a bond condition, does not immunize her from false‑reporting liability when she manipulates the test in order to deceive law enforcement.

Accordingly, the Court:

• Reversed the circuit court’s interpretation of SDCL 22‑11‑9(3); and
• Reinstated the magistrate court’s judgment of conviction on the December 9 count.

Justice Salter’s special concurrence emphasized that:

• Reading into SDCL 22‑11‑9(3) a requirement that the report be unilateral, unprompted, or voluntary would improperly add words to the statute; and
• Categorically exempting deceptive “compliance” communications from the statute would inappropriately intrude on the executive branch’s prosecutorial discretion, contrary to separation‑of‑powers principles.

IV. Detailed Analysis

A. Statutory Framework: SDCL 22‑11‑9

SDCL 22‑11‑9 defines the offense of false reporting to authorities and is divided into three subsections:

1. Subsection (1) concerns causing false emergency alarms (e.g., fire alarms).
2. Subsection (2) prohibits making a report to law enforcement of a crime or incident “knowing that it did not occur.”
3. Subsection (3), at issue here, prohibits making or causing the transmission of a report to law enforcement that furnishes information relating to an offense or other incident within their official concern, “knowing that such information is false.”

The Court notes that:

“False reporting to authorities is a Class 1 misdemeanor.”

While the statute does not define “report,” SDCL 22‑1‑1 instructs that penal statutes are to be construed “according to the fair import of their terms, with a view to effect their objects and promote justice,” a formulation that eschews an overly narrow, defendant‑favored construction when the text is clear.

B. Interpreting “Report” in SDCL 22‑11‑9(3)

1. Method of Interpretation

The Court applied settled principles of statutory interpretation, as summarized in cases it cited:

• The goal is to discover legislative intent (State v. Bettelyoun).
• The starting point is the statutory language itself.
• If the statute’s language is “clear, certain, and unambiguous,” there is no room for judicial construction or policy‑driven narrowing; the court simply declares and applies the statute as written (Armstrong, Bettelyoun).
• Ambiguity exists only when the statute is reasonably capable of more than one meaning (Fluth).
• Statutes must be read as a whole, with words understood in their context within the statute (Bettelyoun).

2. Contextual Definition Rather Than Dictionary‑Driven Narrowing

The circuit court had selected a dictionary definition of “report” that focused on “a formal oral or written presentation,” which led it to conclude that a remote breath submission (and accompanying photograph) was not a report.

The Supreme Court rejected this approach, instead looking to how “report” is used in the text of SDCL 22‑11‑9(3) itself:

“SDCL 22‑11‑9(3) specifies that the report must contain ‘information relating to an offense or other incident within [law enforcement’s] official concern[.]’”

From this, the Court drew two key points:

• The statutory focus is on the content (information relating to an offense or incident) and the recipient (law enforcement authorities) rather than the formality or medium of the communication.
• The text does not distinguish between written and oral reports, nor does it specify any particular format or require that the communication be voluntary, formal, or unprompted.

Thus, the Legislature did not intend “report” to be limited to classic police‑report style statements. Instead, the Court concluded:

“We conclude the Legislature did not intend to limit the application of the word ‘report’ to a specific medium or type of communication.”

3. The Court’s Functional Definition

Using the statutory language as a guide, the Court articulated its operative definition:

“Based on the unambiguous language of SDCL 22‑11‑9(3), we conclude ‘report’ means a communication, ‘which furnishes information relating to an offense or other incident within [law enforcement’s] official concern.’”

The elements of a violation under subsection (3) were summarized as:

1. The defendant makes a report or intentionally causes the transmission of a report;
2. The report is to law enforcement authorities;
3. The report furnishes information relating to an offense or other incident within law enforcement’s official concern; and
4. The defendant knows that such information is false.

This framework is medium‑neutral and conceptually broad enough to encompass electronic, automated, or third‑party mediated transmissions, as long as the defendant intentionally causes the communication to be sent and knows it is false.

C. Application to Remote Breath Testing

1. Intentional Causation of a Report

The Court treated the breath test result and associated photograph as a single communication. It observed that:

• Biteler received explicit instruction on how the unit works, including how the camera function is triggered and the positioning required for a proper photograph.
• She knew that blowing into the machine would cause it to take a picture and automatically send both the test result and photograph to AMS for relaying to law enforcement.
• AMS functioned as a “conduit” between the enrollee and law enforcement, not an independent recipient in a way that would break the chain of causation.

With this knowledge, when she arranged for another person to blow into the machine while she positioned her face for the photograph, she:

• Knowingly triggered the automated reporting process; and
• Intentionally caused a false report about her compliance with the 24/7 order to be transmitted to law enforcement.

The Court emphasized that the breath test result and photograph are a “communication that furnished information of an incident within law enforcement’s official concern—Biteler’s compliance with 24/7 testing.” That is enough to meet the statute’s “report” requirement.

2. Law Enforcement’s “Official Concern”

Another key element is whether the information relates to an “offense or other incident within [law enforcement’s] official concern.” Here, the “incident” was not a discrete crime report but ongoing compliance with a court‑ordered monitoring program in the context of a DUI prosecution.

The Court readily concluded that monitoring compliance with bond conditions in a DUI case is squarely within law enforcement’s official concern. Thus:

• The test result (showing a zero BAC) and the photograph (purporting to show the defendant providing that sample) both related to that incident; and
• The communication therefore fell within the scope of the statute’s “official concern” language.

3. Knowledge of Falsity

Finally, the Court noted that the magistrate court found that:

“The magistrate court found that Biteler falsified her breath test on December 9 by having another person blow into the machine while her face was before the camera, and Biteler has never challenged that finding.”

Accepting this unchallenged factual determination, the knowledge element was satisfied: Biteler knew that the resulting communication falsely represented that the sample was her breath and that she had no alcohol in her system.

D. The Defendant’s “Coercion” and “Compliance” Arguments

On appeal, Biteler argued that SDCL 22‑11‑9(3) should apply only to “affirmative acts of communication initiated by the defendant,” and that her 24/7 submissions were “not a voluntary act of communication to law enforcement. It [was] compliance, not communication.”

The Supreme Court implicitly rejected this framing by:

• Focusing on the intentional causation of the report, not on the voluntariness of the underlying duty to report;
• Recognizing that, even in a compelled setting, the defendant can intentionally manipulate the content of the communication; and
• Refusing to treat the coercive nature of supervision as a blanket shield against false‑reporting liability when the statutory elements are otherwise met.

Functionally, the Court distinguished between:

• Neutral compliance: simply submitting honest data under compulsion; and
• Deceptive compliance: manipulating the process to send false information while appearing to comply.

The statute targets the latter; there is no requirement that the duty to report be voluntary or that the communication be unsolicited.

E. The Concurring Opinion: Separation of Powers and Prosecutorial Discretion

Justice Salter’s special concurrence, joined by Retired Justice Kern, reinforces the majority’s textualist approach and draws out its separation‑of‑powers implications.

1. No Judicial Addition of Textual Limitations

Justice Salter first rejects the defendant’s argument that SDCL 22‑11‑9(3) “contemplates only a unilateral, unprompted report by a defendant.” Doing so would, in his view, “add words to the statute that the Legislature did not include,” which prior cases forbid:

“This Court may not add language to a statute by ‘judicial legislation.’” (Sioux Falls Shopping News, Inc. v. Dep’t of Revenue & Regul., quoting Hannon v. Weber)

In other words, limiting SDCL 22‑11‑9(3) to voluntary or unprompted reports would be a policy choice for the Legislature, not the judiciary.

2. Prosecutorial Discretion and the Executive Function

The concurrence’s second concern is that the defendant’s “compliance not communication” argument effectively asks the Court to carve out a large category of dishonest statements made in response to law‑enforcement questioning—or in fulfillment of legally imposed reporting requirements—from the reach of the statute.

Justice Salter frames this as an invitation for the judiciary to preempt executive‑branch prosecutorial discretion:

“[Biteler’s] claim that her effort to deceive law enforcement officials should be treated merely as ‘compliance’ and not a false ‘communication’ is an invitation to preempt the executive-branch function of prosecutorial discretion.”

He anchors this concern in South Dakota’s constitutional separation of powers (S.D. Const. art. II and art. IV, § 3) and in broader authority recognizing the executive’s “exclusive authority and absolute discretion to decide whether to prosecute a case” (United States v. Nixon; Carson v. Gentry, as quoted).

While judicial review can and must police the limits of the statute (e.g., ensuring that elements such as knowledge and intentional causation are met), it cannot rewrite the statute to categorically remove a class of false statements from prosecutorial reach where the statutory language plainly covers them.

3. Scope of the Decision and Fear of Overbroad Application

Justice Salter notes that the defendant ultimately argues the Court should avoid an interpretation that might allow prosecutors to charge people who give false answers to police questions:

“[S]uch a broad reading of our decision is not justified, but, in any event, interpreting SDCL 22‑11‑9(3) to immunize individuals from prosecution for lying to the police is not a valid judicial response to a question that requires nothing more than reading and applying a statute’s plain and unambiguous text.”

He reiterates the “cardinal rule” of interpretation stated in In re Appeal by Implicated Individual: “simply read the text and apply it.” Concerns about overuse or misuse of the statute are left to the executive branch (through prosecutorial decisions) and the Legislature (which can amend the statute), rather than to judicial revision of unambiguous text.

V. Precedents Cited and Their Influence

A. Statutory Interpretation and Penal Statutes

1. State v. Long Soldier, 2023 S.D. 37

Cited for the standard of review, Long Soldier confirms that issues of statutory interpretation are reviewed de novo. This underpins the Court’s authority to disregard the circuit court’s narrower interpretation and substitute its own reading based on the statutory text.

2. State v. Bettelyoun, 2022 S.D. 14

Bettelyoun provides the overarching interpretive framework:

• The purpose of interpretation is to discern legislative intent.
• The “starting point … must always be the language itself.”
• Where language is clear and unambiguous, the court’s role is limited to declaring and applying it.
• Statutes are read as a whole, avoiding piecemeal reading of isolated words.

Here, that framework leads the Court to reject the circuit court’s dictionary‑based narrowing of “report” and instead derive meaning from the phrase “which furnishes information relating to an offense or other incident within their official concern.”

3. State v. Bryant, 2020 S.D. 49, and State v. Armstrong, 2020 S.D. 6

Both cases reinforce that unambiguous statutory text leaves no room for judicial re‑construction. In Armstrong, the Court explained that when language is “clear, certain, and unambiguous,” “there is no reason for construction.” This supports the majority’s conclusion that “report” is not ambiguous in context, and any policy‑driven narrowing—such as requiring formality, written statements, or voluntariness—would exceed the judicial role.

4. Fluth v. Schoenfelder Constr., Inc., 2018 S.D. 65

Fluth defines ambiguity as arising when a statute is reasonably capable of more than one sense. The Court implicitly finds that, once “report” is read in light of the surrounding statutory language, it has a single, clear sense—communication furnishing relevant information to law enforcement—and thus is not ambiguous.

5. SDCL 22‑1‑1: Interpretation of Penal Statutes

SDCL 22‑1‑1 instructs that:

“[A]ll penal statutes shall be construed according to the fair import of their terms, with a view to effect their objects and promote justice.”

Historically, some jurisdictions construed penal statutes strictly in favor of defendants (the “rule of lenity”). South Dakota’s directive softens that approach: where the terms’ “fair import” is clear, courts apply them to effect the statute’s objects. Here, the object of SDCL 22‑11‑9 is to deter and punish false reports that interfere with law enforcement’s work. Narrowing “report” to exclude digital or compelled compliance communications would undermine that objective.

B. Separation of Powers and Judicial Restraint

1. Sioux Falls Shopping News, Inc. v. Dep’t of Revenue & Regulation, 2008 S.D. 34, and Hannon v. Weber, 2001 S.D. 146

These authorities, quoted in the concurrence, highlight the prohibition on judicial legislation:

“This Court may not add language to a statute by ‘judicial legislation.’”

Justice Salter deploys this principle to show that requiring a “unilateral, unprompted” report is tantamount to inserting extra words into SDCL 22‑11‑9(3)—a step that would conflict with the separation of powers by effectively rewriting the statute.

2. United States v. Nixon, 418 U.S. 683 (1974), and Carson v. Gentry, 574 P.3d 205 (Ariz. 2025)

The concurrence invokes these authorities to frame prosecutorial discretion as a core executive function:

• Nixon is quoted for the proposition that the Executive Branch has “exclusive authority and absolute discretion to decide whether to prosecute a case.”
• Carson is cited (per the quoted portion) for the principle that judicial oversight of prosecutorial discretion generally constitutes inappropriate interference with the executive’s broad discretion.

By emphasizing these cases, the concurrence signals that while courts interpret statutes, they must not curtail the executive’s charging discretion by artificially narrowing unambiguous statutory language.

3. In re Appeal by Implicated Individual, 2021 S.D. 61

This case is cited for the “cardinal rule of statutory interpretation”—“simply read the text and apply it.” Justice Salter uses it to rebut arguments that the Court should shape its reading of SDCL 22‑11‑9(3) to avoid expansive prosecutorial applications; instead, the Court’s duty is to apply the clear text, leaving charging policies to the executive and policy reforms to the Legislature.

VI. Simplifying Key Legal Concepts

A. “Report” and “Communication” in Plain Terms

In everyday language, a “report” is simply information you send to someone so they can know what’s happening. The Court treats “report” in that everyday, functional sense:

• It does not have to be a formal, written narrative.
• It can be electronic, automated, or sent through an intermediary like AMS.
• What matters is that the person’s actions cause information to be communicated to law enforcement.

B. “Intentionally Causes the Transmission of a Report”

This phrase does not require the defendant to hand‑deliver a document to police. Someone “intentionally causes the transmission” of a report if:

• They take an action (e.g., blow into a device) knowing that this action will cause information to be sent to law enforcement; and
• They do so on purpose, not accidentally.

The presence of an automatic system (like AMS) doesn’t change this; pushing the button (or blowing into the device) with awareness of the system’s operation is enough.

C. “Within Law Enforcement’s Official Concern”

This phrase limits the statute to information that reasonably matters to law enforcement in carrying out their duties. It includes:

• False reports about crimes that occurred (or did not occur);
• False tips or leads in an investigation; and
• False information about compliance with court orders (e.g., bond conditions, probation terms) related to criminal cases.

D. Compulsory Reporting Versus Deceptive Reporting

Being required to report (for example, as a bond condition) is not itself criminal. What becomes criminal is:

• Using that reporting system to send false information; and
• Doing so intentionally and with knowledge that the information is false.

The Court’s decision does not criminalize mere participation in supervision programs; it criminalizes intentional deception through those programs.

E. Separation of Powers and Prosecutorial Discretion (Simplified)

“Separation of powers” means each branch of government has its own job:

• The Legislature writes the laws.
• The Executive (including prosecutors) decides when and how to enforce them.
• The Judiciary interprets laws and resolves cases under them.

When a court narrows a clear criminal statute because it dislikes how broad it might be in practice, it risks stepping into the Legislature’s role (by effectively rewriting the law) and the Executive’s role (by limiting which conduct can be prosecuted). The concurrence cautions against that, insisting that courts stick to reading and applying the text.

VII. Impact and Future Implications

A. Immediate Impact on 24/7 and Remote Monitoring Programs

State v. Biteler clarifies that:

• Data and images generated by court‑ordered monitoring devices (like remote breath units) and automatically transmitted to law enforcement can be “reports” under SDCL 22‑11‑9(3).
• Participants who intentionally manipulate these systems—by having someone else submit a sample, tampering with devices, or otherwise falsifying the data—risk criminal liability for false reporting, beyond mere administrative or bond‑condition sanctions.

For 24/7 enrollees and similarly monitored individuals, the case underscores that:

• Interfering with or gaming the monitoring system is not just a “technical violation” but may independently constitute a Class 1 misdemeanor.
• Knowledge that the system transmits data to law enforcement can be inferred from standard instructions given at enrollment.

B. Broader Technological Context: Digital and Automated “Reports”

Because the Court’s definition of “report” is medium‑neutral, the decision has potential implications for:

• Other remote or digital alcohol monitoring systems (e.g., ankle bracelets that measure transdermal alcohol content);
• Remote drug‑testing technologies;
• GPS or electronic monitoring systems for location compliance; and
• Smartphone‑based check‑in or biometric verification systems used in pretrial, probation, or parole contexts.

Where a defendant:

• Knows that their actions will cause data to be transmitted to law enforcement;
• Manipulates the system to transmit false information; and
• Does so intentionally;

those transmissions could qualify as “reports” under SDCL 22‑11‑9(3) if they relate to an offense or incident within law enforcement’s concern.

C. Prosecutorial Charging Decisions and Overlap with Other Offenses

The decision preserves broad prosecutorial discretion. In practice, this means:

• Prosecutors could choose to treat certain monitoring violations strictly as bond or probation violations; or
• In more egregious or intentional deception cases, they could add false‑reporting charges under SDCL 22‑11‑9(3).

The concurring opinion explicitly recognizes that such choices belong to the executive branch, not the judiciary. Over time, patterns in charging decisions may shape how often SDCL 22‑11‑9(3) is invoked in the supervision context.

D. Defense Strategy and Advising Defendants

Defense counsel advising clients in 24/7 or similar programs should now:

• Warn that manipulating monitoring devices or enlisting others to do so can support separate false‑reporting charges.
• Recognize that arguments premised on the “coercive” nature of supervision (claiming the conduct was merely compelled “compliance”) are unlikely to succeed when the client has taken affirmative steps to deceive within that framework.
• Focus on contesting elements like knowledge, intent, or the attribution of the manipulation to the defendant where the evidence is weaker.

E. Doctrinal Significance: Textualism and Penal Statutes

At a higher doctrinal level, Biteler reinforces several themes in South Dakota law:

• A strong textualist approach: courts start with the statutory language and, where it is clear, resist invitations to add policy‑based limitations.
• The “fair import” standard for penal statutes: clear statutory terms are applied to achieve legislative objectives rather than narrowly construed in favor of defendants by default.
• Respect for separation of powers: the judicial role is to interpret and apply statutes, not to manage prosecutorial lines of demarcation through creative interpretation.

As more criminal‑justice functions are mediated by digital technologies, courts will likely continue to face questions about how traditional statutory language applies to new forms of communication. Biteler provides a template: focus on the statute’s text and purpose, not on the technological novelty of the medium.

VIII. Conclusion

State v. Biteler establishes that, under SDCL 22‑11‑9(3), a “report” is any communication that furnishes information to law enforcement about an offense or incident within their official concern, regardless of medium, formality, or whether the communication occurs in a compelled supervision context.

By holding that remote breath test submissions (including their automatically captured photographs) are “reports” when intentionally manipulated to convey false information, the Supreme Court of South Dakota:

• Aligns the false‑reporting statute with the realities of modern, technology‑based monitoring;
• Signals that deceptive “compliance” with court‑ordered programs can carry independent criminal liability; and
• Affirms a commitment to textual interpretation and separation‑of‑powers principles, leaving charging decisions and policy concerns to the appropriate branches of government.

In the broader legal landscape, Biteler will likely serve as an important precedent in South Dakota for future cases involving digital evidence, automated reporting systems, and the application of traditional criminal statutes to technologically mediated conduct. It also provides a clear warning: technological intermediaries do not dilute personal responsibility for intentionally causing false information to be communicated to law enforcement.