State v. Calhoun

226 N.W.2d 504, 67 Wis. 2d 204, 1975 Wisc. LEXIS 1454
CourtWisconsin Supreme Court
DecidedMarch 6, 1975
DocketState 163
StatusPublished
Cited by34 cases

This text of 226 N.W.2d 504 (State v. Calhoun) is published on Counsel Stack Legal Research, covering Wisconsin Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Calhoun, 226 N.W.2d 504, 67 Wis. 2d 204, 1975 Wisc. LEXIS 1454 (Wis. 1975).

Opinions

Robert W. Hansen, J.

While the appeal is from the judgment holding that this defendant cannot be retried, the challenge is to the exercise of discretion by the trial court in granting defendant’s motion for mistrial and directing that defendant be retried. In reviewing the facts and circumstances surrounding the trial court’s granting of defendant’s motion for mistrial, we deal (1) with the consequences of a less than complete compliance with a demand for disclosure under Wisconsin law, and (2) with the applicability of double jeopardy provisions of the state 1 and federal 2 constitutions, as controlled and determined by the decisions of the United States Supreme Court as to mistrial with retrial.

[210]*210 Trial court’s declaring a mistrial.

Where the claim, is one of double jeopardy under a mistrial with retrial order, the United States Supreme Court has held that such cases “. . . turn on the particular facts and thus escape meaningful categorization . ...” 3 The high court makes clear that inquiry as to the facts includes determining whether . . in light of the State’s established rules of criminal procedure, the trial judge’s declaration of a mistrial was not an abuse of discretion. ...” 4 This is particularly so in cases, as the one now before us, in which a mistrial has been declared prior to verdict.5

Three possibilities exist as to the propriety and consequences of the trial court here granting defendant’s motion for a mistrial. The first, urged by the defendant, is that the trial court acted properly in doing what it did, but did not go far enough. Having declared a mistrial, the trial court was here required to accompany the granting of defendant’s motion with an order dismissing the charges. The second possibility, urged by the state on appeal, is that the trial court was entitled to declare [211]*211a mistrial with retrial, and that the judge to whom the case was assigned went too far in finding retrial barred by a double jeopardization. The third possibility, suggested by the state’s brief on appeal, is that the trial court went too far and that a mistrial should not have been declared on the ground and record before the trial court. Making an independent review of the facts and circumstances, we consider all three possibilities.

Four days before the trial began, defense counsel served on the district attorney’s office a demand for disclosure of any evidence in the possession of the state “. . . tending to exculpate the defendant of the commission of this offense, or to minimize his complicity in it.” At the time of the demand, the district attorney assigned to the case had in his possession police notes or summaries regarding: (1) A statement by Ronald Calhoun, son of the defendant, that the victim had reached into his pocket and pulled out a gun immediately before the fatal shooting; and (2) a statement by John Calhoun, also a son of the defendant, to the same effect; and (3) a statement by Rose Wesley, niece or cousin or friend of defendant, that she saw the victim reach into his pocket prior to being shot by the defendant. With self-defense claimed, these statements were exculpatory in nature. In his affidavit in support of the state’s motion to vacate the dismissal, the assistant prosecutor stated that, acting in good faith, he did not furnish these statements to the defense believing that the statements of the two sons and the niece were available to the defendant and that they would say to their father or uncle no less than they said to the police on his behalf. It was the prosecutor’s interpretation of the law in this state that he was not required to furnish exculpatory information to the defendant that was not in the exclusive possession of the state and was equally available to the defense.

[212]*212On the issue of whether a demand for disclosure reaches exculpatory material that is not in the exclusive possession of the state, the trial court did not refer to Wisconsin’s discovery and inspection statute.6 The notice of demand served by the defendant did not refer to such statute, and the demand appears to go beyond what is to be disclosed under the statute.7 Prior to enactment of the statute, this court distinguished between “discovery” and “disclosure.” 8 As to both, it has not been held that the legislature did not codify and implement [213]*213by the statute the full mandate of Nelson v. State,9 which in turn followed the mandate of the United States Supreme Court in Brady v. Maryland.10 We do not here reach or rule on whether the statute controls as to both “discovery” and “disclosure.” However, we would not label as “prosecutorial misconduct” a conclusion of law by an assistant district attorney that the discovery statute was applicable and did not require the furnishing, on demand, of exculpatory material not in the exclusive possession of the state and not relating to statements made by the defendant.11

As to whether exculpatory material, not in the exclusive possession of the state, must be turned over on demand for disclosure, the applicability of the state discovery statute would make no difference. Under that statute, in regard to its witness list exchange requirement, in Irby v. State,12 this court stated the rule to be that, even to secure a recess or continuance for failure to comply with the statute, it is to be established that [214]*214“. . . the defendant be surprised and prejudiced by the testimony. . . 13 Prior to the enactment of the discovery statute, applying the Brady v. Maryland mandate, this court in State v. Cole,14 dealing with a prosecutorial failure to disclose information concerning a gun and the kind of car involved in an arrest, found no error in the failure to disclose and stated: “Certainly defendant was aware of the kind of car and gun involved in her arrest. Therefore, this information was not ‘in the exclusive possession of the state.’ ” 15 At the constitutional level, the exclusive possession prerequisite to the duty to disclose was thus recognized. In Nelson itself, this court discussed cases dealing with “. . . the responsibility of the state in respect to coming forward with exculpatory evidence within its exclusive control and the necessity of a prior request therefor. . . .” (Emphasis supplied.)16 Also, in Nelson, we held that “. . . the duty of the state to disclose exculpatory evidence has not been constitutionally extended to require full disclosure of all evidence helpful to the accused . . . .”17 In support of the holding, we cited, and later in the opinion quoted from, Giglio [215]*215v. United States,18 the United States Supreme Court holding1 that: . . We do not, however, automatically require a new trial whenever ‘a combing of the prosecutors’ files after the trial has disclosed evidence possibly useful to the defense, but not likely to have changed the verdict . . . ” 19

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Bluebook (online)
226 N.W.2d 504, 67 Wis. 2d 204, 1975 Wisc. LEXIS 1454, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-calhoun-wis-1975.