It's outrageous that Mr. Zeller is allowed to continue to flout the criminal justice system," Police Chief Craig Tieszen said.
"Right now it's an interesting news story, but we will all be outraged when he kills somebody on (DUI) number 35."
Some entries on Zeller's criminal record might be duplicates, said Kara Wood, deputy state's attorney in Pennington County. By Wood's count, Zeller has been arrested 16 times and convicted nine times since 1980.
But she added, "I just don't have an accurate number."
Zeller's latest arrest was his second in five months, she said.
A police report said a breath test on Zeller during Tuesday's arrest indicated a blood alcohol content of 0.286 percent. The South Dakota limit is 0.08 percent.
Update: Changed number of dwis to 34. 35 is next.