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S.D. Codified Laws § 22-18-2

Justifiable force used by public officer in performance of duty--Assistance or direction of officer

Applied in 8 court decisions — leading case United States Means v. Solem (1980)

Most recently applied in State v. Warfield (March 2026)

Source: SDC 1939, § 13.2402 (1); SL 2005, ch 120, § 6.

How often courts cite this section

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citing decisions per year

Court decisions citing this, by year. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.

To use or attempt to use or offer to use force or violence upon or toward the person of another is not unlawful if necessarily committed by a public officer in the performance of any legal duty or by any other person assisting the public officer or acting by the public officer's direction.

Official source: South Dakota Legislature. Reproduced from public-domain South Dakota statutes; confirm against the official source for the current text. Not legal advice.