CRIMINAL PROCEDURE
Natalie Howard
Hedrick v. State
In Hedrick v. State, 474 P.3d 4 (Alaska Ct. App. 2020), the court of appeals upheld a criminal defendant’s waiver of his right to a jury trial because the trial judge had adequately advised him of his right. (Id. at 5). Hunter Hedrick was charged with multiple felony assaults for an unprovoked attack on a hotel security guard and concierge. (Id. at 5–6). During a status hearing, Hedrick’s attorney indicated he wished to waive his right to a jury trial. (Id. at 6). The trial judge addressed Hedrick personally and determined he made “a free, voluntary, and knowing decision,” and Hedrick signed a written waiver listing the offenses charged. (Id.). The judge ultimately found Hedrick guilty on all counts. (Id. at 7). On appeal, Hedrick argued his waiver was invalid because the trial judge failed to adequately advise him. (Id. at 5). Under Alaska Criminal Rule 23(a), criminal defendants may waive their constitutional right to a jury trial as long as there is a written waiver and “adequate personal inquiry” to ensure it is voluntary and knowing. (Id. at 7). Here, Hedrick executed both a written and oral waiver, and was personally and specifically instructed regarding the consequences of his decision. (Id. at 7–8). It was sufficient that the trial judge had explained that he was agreeing to have the judge decide his guilt; the court was not required to go into any more detail about the important features of a jury trial nor the specific elements of the charged offenses. (Id. at 8–9). Thus, the court of appeals held the trial judge had indeed adequately advised Hedrick of his right to a jury trial. (Id. at 5). In concurrence, Judge Wollenberg agreed with the holding but emphasized that, as a matter of best practice, trial judges are still strongly encouraged to describe all the salient features of a jury trial to criminal defendants. (Id. at 11 (Wollenberg, J. concurring))
