Alexander v. State

Facts

In Maryland, two inmates, Ralph Alexander (Defendant) and Bruce Shreeves, were charged with assault on a correctional officer, Dale Tscheulin. According to the State’s witnesses who testified at trial, Shreeves first attacked Tscheulin and Defendant later joined to assist in the assault. However, according to Defendant’s witnesses, another correctional officer, Samuel Stokes, Jr., grabbed Shreeves from behind without any provocation, and then Tscheulin came and started hitting Shreeves. As a result, Defendant told Tscheulin that he did not have to hit Shreeves, and Tscheulin subsequently turned around to hit Defendant. Defendant claims that he simply grabbed the bars and pinned Tscheulin between himself and the bars, but did not hit Tscheulin. Tscheulin and Stokes claim that as they were subduing Shreeves, Defendant came to the scene, jumped on Tscheulin, and struck Tscheulin in the chest and head. At trial, the judge instructed the jury on Shreeves’ right of self-defense and Defendant’s right of self-defense. The judge added: “[I]f Shreeves had the right to defend himself, then [Defendant] had the right to go help him defend himself; if Shreeves did not have the right to defend himself, then [Defendant] didn’t have the right to go help Shreeves defend himself. He stands in the same shoes as Shreeves when he elects to come to his assistance.” After, the judge told the jury that if they find that Shreeves is not guilty because he had a right of self-defense, then they must also find that Defendant is not guilty because Defendant would have that same right of self-defense regarding Shreeves; and if the jury finds Shreeves did not have the right of self-defense, then Defendant cannot claim the right of self-defense on the basis that he was trying to protect Shreeves. Defendant was convicted in the Criminal Court of Baltimore; he subsequently appealed to the Court of Special Appeals of Maryland.