State of Maine v. William A. Wiley
61 A.3d 750
Me.2013Background
- Wiley was convicted after a jury trial on seven Class C unlawful sexual contact counts and three Class B counts; appeal followed.
- Stepdaughter, age 18, reported Wiley's sexual contact with her when she was about 12, prompting police investigation on April 15, 2009.
- Detective Bosco interviewed Wiley at Wiley's residence, then at the sheriff's office in an interview room; Wiley was not Mirandized before questioning.
- The interview was recorded; Wiley initially denied wrongdoing and showed emotional distress, including crying and a fetal-position posture.
- Detective suggested leniency via a short jail sentence with probation if Wiley confessed; Wiley was later arrested and Mirandized.
- The suppression court denied the motion to suppress, ruling Wiley was not in custody and his pre-arrest statements were voluntary; on appeal, the court vacated and remanded for new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there custodial interrogation triggering Miranda? | Wiley contends he was in custody during the interview and not Mirandized. | State argued no custody existed; statements were voluntary and Miranda not required. | No custodial custody found; Miranda not required. |
| Were Wiley's statements voluntary given inducements and distress? | Det. Bosco’s promises of leniency induced confession; distress rendered it involuntary. | Confession voluntary; inducements were within allowable investigatory technique and not the sole motive. | Confession not voluntary; inducements and state actions made it involuntary; judgment vacated. |
Key Cases Cited
- State v. McCarthy, 2003 ME 40 (Me. 2003) (voluntariness standard; burden on State beyond reasonable doubt)
- State v. Lavoie, 2010 ME 76 (Me. 2010) (promises of leniency not per se coercive; focus on state of mind)
- State v. Dodge, 2011 ME 47 (Me. 2011) (deferential, fact-based review; totality of interrogation factors)
- State v. Sawyer, 2001 ME 88 (Me. 2001) (promises or inducements; coercion analysis)
- State v. Farnham, 479 A.2d 887 (Me. 1984) (sentencing considerations; mitigation factors not controlling)
- State v. Tardiff, 374 A.2d 598 (Me. 1977) (promises of leniency addressing confessions)
- United States v. Villalpando, 588 F.3d 1124 (7th Cir. 2009) (promises of leniency vary in coercive impact; focus on state of mind)
- Delaney v. United States, 443 Fed.Appx. 122 (6th Cir. 2011) (causation/voluntariness considerations in coercion analysis)