State of Minnesota v. Clark

Courtney Clark (plaintiff) was under investigation for murder. The police interviewed Clark three times, once before arraignment and twice afterwards. The first interview was on July 26, before Clark’s arraignment and before he had been appointed an attorney. After the interview, Clark was arraigned and appointed a public defender, Tom Handley. Later that day, Clark asked to speak to the police, and the police interviewed Clark a second time. According to police testimony, the public defender’s office was aware that the police were going to interview Clark. Several times after July 26, the prosecutor, Charles Balck (defendant) stopped the police from interviewing Clark without Handley present and attempted to contact Handley to arrange an interview in Handley’s presence. On August 3, Clark asked again to speak to the police. Balck left a message for Handley, stating that Clark wanted to speak to the police and the police were going to interview Clark. The police then interviewed Clark without Handley present. At trial, Clark moved to suppress the statements he made after his arraignment on July 26 and on August 3, and the court overruled the motion. Clark was convicted, and he appealed, arguing that Balck violated Minnesota Rule of Professional Conduct 4.2 (MRPC 4.2) and as a result, Clark’s motion to suppress should have been granted.