Shiflett v. State
146 A.3d 504
Md. Ct. Spec. App.2016Background
- Shiflett killed Katie Hadel in her apartment on Feb. 5, 2013; he faced multiple murder and burglary charges and contested premeditation.
- Prior to trial, Shiflett’s mental illness was considered but not admitted as evidence; a mid-trial competency hearing found him competent.
- During trial, Shiflett behaved disruptively; the court ordered a stun cuff, which he refused, leading to trial proceeding in his absence.
- Trial record showed threats toward the judge and prosecutor, and a scuffle with deputies occurred; security concerns driven the cuff decision.
- Jury convicted Shiflett of first-degree murder (premeditated and felony), with various other counts; he was sentenced to life without parole; he appeals multiple rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether stun cuff restraints were properly imposed and applied | Shiflett contends restraints violated due process and were excessive | State argues restraints were necessary for safety and order given conduct | Court did not abuse discretion; restraints justified by safety concerns and orderly proceedings |
| Whether life-without-parole sentencing required jury determination | Shiflett claims CR § 2-304(b) jury sentencing applies to life without parole | Bellard governs; death-penalty repeal did not create jury-sentencing rights for non-capital murder | Court correctly denied jury sentencing; no right to jury determination for life without parole in non-capital murder |
| Whether evidence of psychological profile was admissible to negate mens rea | Dr. Brandt’s testimony would show lack of mens rea due to illness | Testimony lacks rational nexus to premeditation; would confuse jury | Excluded; no rational nexus; testimony would not aid jury on mens rea |
| Whether Shiflett was competent to stand trial despite disruptive behavior | Competence questioned due to disorders and conduct | Doctors testified to competence; trial court credited some but weighed conflicting opinions | Court properly found Shiflett competent beyond reasonable doubt |
| Whether burglary count was duplicative or improperly charged | First-degree burglary charging used statute without specifying intent | Indictment complied with CR § 6-210; referenced CR § 6-202; notice adequate | Charge not duplicative; indictment sufficiently charged burglary under applicable statute |
Key Cases Cited
- Wagner v. State, 213 Md. App. 419 (Md. Ct. App. 2013) (restrains may be used to maintain courtroom security; not per se unconstitutional)
- Hunt v. State, 321 Md. 387 (Md. 1990) (court may consider security measures; balancing test applied)
- Allen, 397 U.S. 343 (U.S. 1970) (court may remove, bind, or gag disruptive defendant to preserve proceedings)
- Illinois v. Allen, 397 U.S. 343 (U.S. 1970) (disruptive defendant may be excluded; alternatives exist but not required)
- Smith v. State, 382 Md. 329 (Md. 2004) (cited for discretion to manage courtroom security effects)
- Bellard v. State, Md. App. (Md. App. 2016) (rejected jury sentencing right for life without parole in non-capital murders)
- Hartless v. State, 327 Md. 558 (Md. 1992) (psychological profile must have rational nexus to issue of premeditation/intent)
- Bryant v. State, 163 Md. App. 451 (Md. 2005) (tests whether psychological testimony has nexus to specific intent; often excluded)
- Jones v. State, 303 Md. 323 (Md. 1985) (indictment may be by reference to statute; elements implied)
- Whitehead v. State, 54 Md. App. 428 (Md. 1983) (incorporation by reference can charge by statute number)