United States v. Wrensford, No. 16-1373 (3d Cir. 2017)Annotate this Case
Wrensford and Muller had an altercation with a man at a car wash. Hours later, the man returned with Hendricks. A truck passed the car wash, turned around, and chased Hendricks. The passenger (Wrensford) fired several shots. Hendricks died from gunshot wounds. Officer Mendez drove in the direction that witnesses said the truck was going, and 45 minutes later, encountered two men walking on the road. Before he could approach, both men ran. Mendez broadcast a general description. Officer Cruz heard the transmission that two “black, rasta males” were on the run. Cruz thereafter saw a “rasta guy,” drew his gun, ordered Wrensford to get on the ground. Wrensford was transported to the police station. Officers later recovered a pistol close to where Wrensford had been standing. Witnesses, taken to the police station, saw Wrensford and “blurted out” that they saw the shooter (Wrensford) outside the station. They identified Muller from a photo array. The Third Circuit vacated Wrensford’s conviction for determination of whether an exception to the Fourth Amendment applies and renders the identification evidence admissible; Wrensford was de facto arrested when, without probable cause, he was transported to the police station. The court affirmed as to Muller; he waived his challenge to the suppression rulings. The court did not abuse its discretion by polling the jury and instructing it to redeliberate, or refusing to give a voluntary manslaughter jury instruction.