State v. Slaughter
152 A.3d 1275
| Del. Super. Ct. | 2017Background
- Delaware indicted Jason Slaughter for 1st‑degree murder (Dec. 2007). He was incarcerated in Georgia serving life for another murder when Delaware lodged a detainer (Oct. 2013).
- Slaughter delivered a UAD/IAD request to Georgia prison officials in Oct. 2013; Georgia forwarded it to Delaware DOJ but the Superior Court did not receive actual notice.
- Delaware, believing (mistakenly) the UAD did not apply to capital cases, obtained custody via a Governor’s Warrant and Slaughter was brought to Delaware (Oct. 9, 2014).
- Slaughter filed multiple motions to dismiss alleging UAD/IAD violations: (1) failure to accept temporary custody under §2544 (after his §2542 prisoner request), and (2) failure to try him within 120 days under §2543 (relying on Mauro).
- Court held hearings on the motions, received corrected disclosure that Delaware personnel had misadvised Georgia about the UAD, but ultimately denied dismissal.
Issues
| Issue | Plaintiff's Argument (Slaughter) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether the indictment must be dismissed under §2544 because the State refused/failed to accept temporary custody after Slaughter’s §2542 request | State refused to accept custody under UAD by rejecting his §2542 request and using a Governor’s Warrant instead; dismissal required | Slaughter never perfected his §2542 request to the court (actual delivery), so UAD protections never vested | Denied — court found Slaughter did not cause actual delivery to the Superior Court, so §2542 rights never vested and §2544 dismissal not available |
| Whether issuance of a detainer plus Governor’s Warrant triggered §2543 (Mauro) and the 120‑day trial clock, requiring dismissal for delay | Detainer plus written Governor’s Warrant constituted a written request for temporary custody triggering §2543 and 120‑day limit; State missed the deadline | State contended Governor’s Warrant is not the §2543 “written request”; alternatively, Slaughter waived any §2543 right by requesting trial outside the 120‑day window | Denied — court did not decide Governor’s Warrant issue but held Slaughter waived any §2543 speedy‑trial claim by counsel’s request for a trial date beyond 120 days |
| Whether Slaughter’s §2542 prisoner request was effective despite prison officials failing to send it to the court | Substantial compliance: prison forwarded request to DOJ, prosecutor knew, so dismissal appropriate | U.S. Supreme Court and Delaware precedent require actual receipt by both prosecutor and court; §2542(g) confirms actual receipt required | Held for State — actual delivery is required; Slaughter failed to ensure Superior Court received notice, so §2542 did not commence |
| Whether any §2543 timing error was harmless or excused | Timing violation mandates dismissal | Even if timing triggered, counsel requested trial dates beyond the statutory window; also scheduling realities and case complexity would have supported continuance (good cause) — error harmless | Held for State — waiver by counsel; alternatively any timing error was harmless and UAD policy concerns not implicated (Slaughter serving life in GA) |
Key Cases Cited
- United States v. Mauro, 436 U.S. 340 (1978) (distinguishes a detainer from a separate written request for temporary custody; both are required to trigger Article III 120‑day rule)
- Fex v. Michigan, 507 U.S. 43 (1993) (IAD 180‑day period begins only upon actual delivery of the prisoner’s request to the prosecutor and court)
- New York v. Hill, 528 U.S. 110 (2000) (defendant may waive IAD rights by agreeing to trial dates outside statutory periods; counsel’s agreement can bind defendant)
- Bruce v. State, 781 A.2d 544 (Del. 2001) (Delaware follows Hill; continuances requested by defense within IAD period toll rather than waive the period)