The South Dakota Supreme Court has overturned the indecent exposure conviction of a man who was caught having relations with a mannequin in the Washington Pavilion of Arts and Science in Sioux Falls. The conviction must be overturned because evidence did not show Michael James Plenty Horse (yes that is his name) specifically intended to arouse or gratify the sexual desire of himself or anyone else by exposing himself in public.

Plenty Horse, now 20, was caught in November 2005. For the full story, click here It establishes a new area of man/mannequin case law that most hope will be left at a single case entry. Yet, the question now is whether Plenty Horse can recover for loss of consortium.