Commonwealth v. Wilkins

82 Va. Cir. 20, 2010 Va. Cir. LEXIS 318
CourtAugusta County Circuit Court
DecidedApril 19, 2010
DocketCase No. CR09000388-00
StatusPublished

This text of 82 Va. Cir. 20 (Commonwealth v. Wilkins) is published on Counsel Stack Legal Research, covering Augusta County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Wilkins, 82 Va. Cir. 20, 2010 Va. Cir. LEXIS 318 (Va. Super. Ct. 2010).

Opinion

By Judge Victor V. Ludwig

This matter comes before the Court on the Defendant’s Motion to Suppress Confession. Defendant, Timothy Wilkins, moves the Court to exclude from evidence at trial any statements made by him at the time of his apprehension and arrest. Specifically, Wilkins seeks to exclude post-Miranda statements which he made during video-recorded questioning following his arrest on the grounds that the statements were not voluntarily made. On April 16, 2010, the Court heard arguments on the matter and viewed the taped statements at issue. After carefully considering the Defendant’s Motion, the Commonwealth’s brief in opposition, and the evidence and arguments presented at the hearing, the Court denies the Motion.

Facts

On June 12, 2009, Augusta County Sheriff’s deputies responded to a report of a man acting suspiciously in a parking lot in Verona, Virginia. One of the responding deputies knew the man to be Wilkins and knew that he had been issued a permit to carry a concealed weapon. When the deputy inquired of Wilkins whether he was armed, Wilkins motioned to the rear of his vehicle and ultimately gave consent to the deputy (and another deputy [21]*21who had had arrived) to open the vehicle door. Having done so, the deputies discovered the body of a dead woman covered with a tarp. The deputies immediately placed Wilkins in investigative detention and advised him of his Miranda rights. The deputies then transported Wilkins to the August County Sheriff’s Office, where he was questioned by Sheriff’s investigators. In the course of this questioning, Wilkins confessed to the murder of the woman found in his vehicle, whom he identified as his girlfriend, Misty Phillips.

Analysis

Even when a suspect has been advised of rights as required by Miranda v. Arizona, 384 U.S. 436, 475-76 (1966), his statements are inadmissible if made involuntarily. See Mincey v. Arizona, 437 U.S. 385, 402 (1978); see also Miller v. Fenton, 474 U.S. 104, 110 (1985). The burden rests with the Commonwealth to prove, by a preponderance of the evidence, that Wilkins’s statements were given freely and voluntarily. See Wilson v. Commonwealth, 13 Va. App. 549, 554 (1992).

The principal evidence offered by the Commonwealth is the video tape of the disputed statements. In some respects, the tape of the interview indicates that Wilkins may have suffered some degree of impairment. For example, at times, he requested that the interviewers repeat questions, he was confused about the details of his arrest, and occasionally he had trouble answering clearly. For instance, Wilkins was unclear where he was initially arrested, ultimately concluding that they had apprehended him in the parking lot of Wal-Mart, though he was actually apprehended in the parking lot of the Food Lion in Verona. Some of his responses were inaudible or unintelligible, but that could as easily have been a result of the quality of the recording, the fact that Wilkins simply mumbled some of his responses, or the understandable probability that, under the circumstances, he sometimes began speaking without having fully formulated in his mind how most clearly to express himself.

However, the Commonwealth need not prove that Wilkins was not impaired to any degree (however minimal) at the time of the statements. Yarborough v. Commonwealth, 217 Va. 971, 974 (1977) (“Statements made during a custodial interrogation and while intoxicated are not per se involuntary or inadmissible.”). The test is whether the defendant’s “will was overborne” or whether the statements were the “product of a rational intellect and a free will.” Id. (quoting Townsend v. Sain, 372 U.S. 293, 307 (1963)). “In determining whether an accused’s will has been overborne, courts assess ‘the totality of all the surrounding circumstances’.” Stockton v. Commonwealth, 227 Va. 124, 140 (1984) (quoting Schneckloth v. Bustamonte, 412 U.S. 218, 225 (1973)). This includes the defendant’s [22]*22background, experience, mental and physical condition, and the conduct of the police. Commonwealth v. Peterson, 15 Va. App. 486, 488 (1992).

In spite of some ambiguous suggestions of impairment, the recording on the whole indicates that Wilkins was not so impaired as to preclude a voluntary confession. On the contrary, Wilkins was cogent and cooperative with the deputies, and he was able to recall the circumstances regarding Ms. Phillips’s death in considerable detail, in spite of the fact that, by his own admission, he was intoxicated when the incident occurred. For instance, he recalled the approximate time that he killed Ms. Phillips; he recalled what the two had been doing at that time; he recalled with some precision where the incident took place; and he recalled in some detail how he killed Ms. Phillips. Wilkins also recalled other facts not related to the incident, such as names and addresses (although his recall was not total in that respect). He expressed regret for his actions, and he attempted to excuse or explain what he had done by stating that he was “a mean drunk” and asserting that he suffered from bipolar disorder. Furthermore, other than an instance of his being unsteady on his feet (which could have been caused by the close quarters of the interrogation room), Wilkins showed little or no sign of physical impairment.

Thus, while his manner of speech during the interview suggests the possibility that he was under the influence of some drug or intoxicant, Wilkins’s physical dexterity and the substance of his responses indicate that he was not so impaired that the confession was involuntary. A suspect questioned after law enforcement authorities discover his deceased girlfriend in the back of his car is likely to be nervous, tired, overwrought, depressed, filled with remorse, or frightened. These conditions may manifest themselves as signs of impairment. But in this case, although there were some arguable indicia of impairment, Wilkins was able to comport himself physically and provide considerable detail about the incident in question, and the totality of the circumstances indicates that he spoke voluntarily and with rational understanding.

The recording also indicates that the conduct of the investigators who conducted the interview did not rise to the level of being coercive and defeating Wilkins’s free will. “Evidence of coercive police activity ‘is a necessary predicate to the finding that a confession is not voluntary.’. . .” Commonwealth v. Peterson, 15 Va. App. 486, 488 (1992) (quoting Colorado v. Connelly, 479 U.S. 157, 164 (1986)). Thus, even if the defendant’s “ability to withstand the coercion is reduced by intoxication, some level of coercive police .activity must occur before a statement or confession can be said to be involuntary.” Id. (emphasis added).

It has been said that “custodial interrogation is . . . inherently coercive.” See e.g., Johnson v. Trigg,

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Related

Rogers v. Richmond
365 U.S. 534 (Supreme Court, 1961)
Townsend v. Sain
372 U.S. 293 (Supreme Court, 1963)
Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Schneckloth v. Bustamonte
412 U.S. 218 (Supreme Court, 1973)
Mincey v. Arizona
437 U.S. 385 (Supreme Court, 1978)
Miller v. Fenton
474 U.S. 104 (Supreme Court, 1985)
Colorado v. Connelly
479 U.S. 157 (Supreme Court, 1986)
Norman J. Johnson v. Clarence Trigg
28 F.3d 639 (Seventh Circuit, 1994)
Sellers v. Commonwealth
584 S.E.2d 452 (Court of Appeals of Virginia, 2003)
Boggs v. Commonwealth
331 S.E.2d 407 (Supreme Court of Virginia, 1985)
Commonwealth v. Peterson
424 S.E.2d 722 (Court of Appeals of Virginia, 1992)
Stockton v. Commonwealth
314 S.E.2d 371 (Supreme Court of Virginia, 1984)
Yarborough v. Commonwealth
234 S.E.2d 286 (Supreme Court of Virginia, 1977)
Wilson v. Commonwealth
413 S.E.2d 655 (Court of Appeals of Virginia, 1992)

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Bluebook (online)
82 Va. Cir. 20, 2010 Va. Cir. LEXIS 318, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-wilkins-vaccaugusta-2010.