STATE v. CARLTON WALLACE, SC 17759
Judicial District of New Haven
Criminal; Whether Trial Court Should Have Suppressed Statement That Defendant Made in South Carolina While Awaiting Extradition; Whether Trial Court Properly Instructed Jury as to Application of Reasonable Doubt Standard to Self-Defense Claim; Whether Antideadlock Instruction Coerced Jury into Returning Verdict. In connection with a shooting that occurred in New Haven, the state charged the defendant with murder and carrying a pistol without a permit, among other things. The defendant, who was located and arrested in South Carolina, agreed to waive all formal extradition proceedings and return to Connecticut to answer the charges against him. New Haven police officers subsequently met with the defendant in South Carolina, where they read him his Miranda rights and began to interrogate him. Shortly thereafter, the defendant gave a taped statement regarding the shooting. Prior to trial, the defendant moved to suppress that statement. He claimed that he was arrested without a warrant as a fugitive from justice, that he was detained unlawfully and that at the time of his interrogation, he had never been presented in court. He therefore argued that the failure to bring him before a court of law following his warrantless arrest in South Carolina violated his constitutional right to counsel. He also argued that his statement was made without a voluntary, knowing and intelligent waiver of his Miranda rights. In denying the defendant's motion, the trial court noted that in South Carolina, fugitives do not go before a judge and that other than the waiver of extradition form itself, there is no additional form advising a fugitive as to his rights regarding extradition. It further noted that while a fugitive is waiting to be picked up by the demanding state, the fugitive is not represented by a public defender. Observing that the defendant had been given his Miranda rights by the New Haven detectives, it concluded that the defendant's waiver of those rights was knowing and voluntary; that his taped statement was freely, voluntarily and knowingly made; and that there was no indication that he wanted to speak to an attorney. The matter then proceeded to trial, and the defendant asserted a claim of self-defense. After the jury began its deliberations, it informed the court that it was deadlocked. The court instructed the jury to continue with its deliberations and try to reach a unanimous decision. The next day, the jury informed the court that it was still deadlocked. The court then gave the jury an antideadlock instruction, and the jury ultimately found the defendant not guilty of murder, but guilty of the lesser included offense of manslaughter in the first degree, and guilty of carrying a pistol without a permit. In this appeal, the Supreme Court will determine whether the trial court properly denied the defendant's motion to suppress and properly failed to instruct the jury that the state had to disprove the self-defense claim beyond a reasonable doubt. It will also determine whether the trial court's antideadlock instruction coerced the jury into returning a verdict.