McDaniel v. State

Citation: 446 So. 2d 670

Court: Court of Criminal Appeals of Alabama; October 31, 1983; Alabama; State Appellate Court

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Terry Wade McDaniel was convicted of manslaughter for the stabbing death of Michael McLaughlin. The incident occurred on February 4, 1982, after both individuals had been drinking. McDaniel was sentenced to 16 years in prison following a sentencing hearing that included evidence of two prior felonies. A key issue raised by the appellant was whether Officer Charles Estes had probable cause for McDaniel's arrest. The court examined whether Estes could rely on information from his superior, Sergeant Manuel R. King, who had received a call from Jean McDaniel stating that Terry had confessed to cutting someone and was unsure of the victim's status. Sergeant King informed Officer Estes, who was investigating a related auto accident, of McLaughlin's death and directed him to arrest McDaniel at the Elk's Club. King had also received a pocket knife from Estes, which bore a substance resembling human blood. King testified about a prior hostile relationship between McDaniel and McLaughlin, including McDaniel's previous threats to kill McLaughlin. There was some inconsistency between King's trial testimony and his earlier statements. The court referenced U.S. Supreme Court precedents regarding the reliance of arresting officers on information from superiors and the credibility of informants.

The trial judge's decision regarding the appellant's arrest and subsequent statement is upheld, as the judgment is deemed deserving of significant weight on appeal. The court found that Officer Estes had probable cause for the arrest based on the evidence presented. The appellant, Terry McDaniel, argued that his statement to the police was involuntary due to inadequate advisement of his constitutional rights and a failure to honor his request for counsel. However, evidence showed he was read his Miranda rights and informed of the murder charge by Officer Mosely, who also testified that no coercive tactics were used during the interrogation. 

The appellant, a healthy 24-year-old, did not demonstrate any physical or mental incapacity at the time. While he claimed to have been upset and requested an attorney, officers noted he was allowed a phone call, during which his father communicated legal advice against making a statement. The father visited shortly after the call, relaying this information to McDaniel; however, McDaniel did not formally ask to see a lawyer. Despite his assertion of confusion regarding the events, he acknowledged discussing matters with the officers and his parents at the jail. The statement, made around 9:35 p.m. on February 4, 1982, detailed an altercation with the deceased, who allegedly brandished a knife, prompting McDaniel to stab him. Although a steak knife was found in the victim's vehicle, no evidence was presented that directly contradicted McDaniel's account. The trial court concluded that McDaniel's statement was given voluntarily and with proper understanding of his rights, affirming the trial judge's findings.

The appellant claimed that the jury should have been instructed on criminally negligent homicide, arguing self-defense in the death of the victim. This request was denied based on the evidence presented, with references to relevant case law supporting this decision. Additionally, the appellant's proposed charge contained a misspelling of "homicide," which also warranted rejection. The trial judge granted some of the appellant's requested charges while properly refusing others, determining they were either redundant, irrelevant, or incorrect in law.

The appellant further contended that his sentencing was improper because the trial court considered felony convictions predating the current Alabama Criminal Code, effective January 1, 1980. The court upheld the constitutionality of the Alabama Habitual Felony Offender Act, rejecting claims that it violated the U.S. Constitution's prohibition against cruel and unusual punishment. The court confirmed the trial court's authority to consider the appellant's prior convictions for grand larceny and escape when imposing the sentence.

The appellant also argued that the judgment for the escape charge did not comply with Amendment 37 of the Alabama Constitution, but the court found no indication of non-compliance in the documentation provided. Ultimately, the court found all arguments made by the appellant to lack merit and affirmed the lower court's judgment. All judges concurred in this decision.