State v. Danielson

Trent Danielson (defendant), a mechanic at Rocket Lube in South Dakota, was fired because Rocket Lube believed Danielson did not submit checks to Rocket Lube that Danielson had received for work completed on cars belonging to Dr. Tom Cox. Danielson was indicted and tried by a jury on one count of grand theft. The government (plaintiff) argued at trial that the checks Danielson had received from Dr. Cox were the property of Rocket Lube. Danielson testified that he had replaced a part in the automatic transmission of Cox’s pickup truck and that Cox, who felt Rocket Lube was overcharging, had asked Danielson to complete the repair work independently of Rocket Lube in his own free time. Danielson argued in his defense that the checks belonged to him. Cox testified that he had believed Danielson was acting for Rocket Lube when Danielson had worked on Cox’s cars. The jury acquitted Danielson of grand theft. Danielson was then indicted for perjury for allegedly falsely testifying under oath that he had replaced transmission parts in Cox’s pickup truck. A jury found Danielson guilty of perjury. The language of South Dakota’s perjury statute required that a person “intentionally” make a material false statement. Danielson appealed, arguing the jury had insufficient evidence to find that his statement was material or that he had the specific intent necessary for a perjury conviction under the statute.