Dalton Green owns a butcher shop in a small town. Early one evening, a young woman named Emily Harris is found murdered in an alley just a block away from Green’s store.

Karen Neal, an eyewitness, initially reported to the police that she saw a medium build black man with a beard and wearing a gray hoody running from the alley moments before Harris’ body was found.

According to the reports, shortly after Harris’ body was found, officers received an anonymous tip claiming that Dalton Green had been arguing with Emily Harris earlier that day over an alleged unpaid debt she owed him.

Detectives Samantha Brooks and James Miller are assigned to investigate the case. Detective Miller is rumored to have been disciplined for engaging in coercive interrogation tactics and allegations of racism. It is believed Miller was paired with Detective Brooks because of her specialized training on implicit bias.

Later in the evening of Harris’ death, the detectives visit Dalton Green’s store to question him. Upon arrival, they observe Dalton through the store window “appearing nervous” and “hastily trying to close the shop.” There is a “Closed” sign hanging on the store’s front door.

Claiming he heard a noise that “sounded like someone fleeing,” Detective Miller opens the unlocked front door and enters the store. He walks through the store and into the back room, passing through a door marked “Employees Only.” While in the backroom Det. Miller finds a knife that appears to have blood on it.

He locates Dalton in the backroom area and places him in handcuffs “for officer’s safety” and brings him out the front door, walking him by a nearby police cruiser where Ms. Neal is seated. Ms. Neal is asked if Dalton is the person she saw running from the alley, she indicates he is. 

Dalton Green is a clean-shaven black man of average build and height. The area near his shop is a busy area where numerous people generally fitting the description given my Ms. Neal would be found.

An autopsy is performed on Ms. Harris indicates she died from a single 8 inch stab wound to her neck. Her death was ruled a homicide.

Draft a two-page memorandum that addresses the following tasks

1. Create an action plan with recommendations for potential witnesses to be interviewed, locations to be examined, records and evidence to be gathered, and field investigation to be conducted. Include a brief description of the type of information to be sought from each potential witness/location/avenue of investigation.

2. List five key questions about the facts that you would prepare to ask Dalton Green that would help build your defense and describe why those questions are important; and

3. Identify areas for legal research and potential legal challenges given the fact pattern.