State v. Wilson
149 N.M. 273
N.M.2010Background
- Michael Wilson was convicted by a jury in Farmington of one count of first-degree child abuse resulting in death for suffocating a two-year-old foster child, Tyler.
- Tyler died after Wilson allegedly smothered him with a blanket while alone with him at Wilson’s home; no signs of external trauma were found.
- Dr. Holmes testified Tyler was in normal health the day before death, suggesting death resulted from external causes rather than natural illness.
- Wilson repeatedly called 911 for CPR attempts; Tyler initially survived resuscitation attempts but died approximately 30 minutes after arrival at the hospital.
- Wilson confessed in police interviews (Feb. 7, 2007) to suffocating Tyler and provided details, including a doll-and-blanket reenactment and handwritten letters.
- The State introduced multiple corroborating data points beyond the confession, including medical testimony, misrepresentations about Tyler’s medical history, and behavioral indicators after the death.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Corpus delicti established? | Wilson's confession was the sole indicator; death could be natural. | Independent evidence insufficient to establish homicide apart from confession. | Corpus delicti established with corroborating independent evidence. |
| Admissibility of Dr. Nolte's smothering opinion? | Nolte based on confession and police report; unreliable. | Testimony based on medical record, autopsy, confession, and police report; admissible. | Admissible; gatekeeper function satisfied; testimony helpful and reliable. |
| Validity of confession under the Fifth/Fourteenth Amendments? | Interrogation occurred while potentially coercive; Miranda issues. | Confession coerced or involuntary. | Confession admissible; no Miranda violation; not involuntary. |
| Harmless error for admission of the expert? | Nolte's testimony unduly influences the jury. | Error could affect the verdict. | Harmless error; substantial corroborating evidence supports conviction. |
| Cumulative error doctrine | Consider errors cumulatively to undermine conviction. | Multiple errors warrant reversal. | Cumulative error doctrine does not apply; no reversible error found. |
Key Cases Cited
- State v. Weisser, 141 N.M. 93 (2007-NMCA-015) (modern corpus delicti with trustworthiness approach)
- State v. Sosa, 129 N.M. 767 (2000-NMSC-036) (corpus delicti requires death and criminal act; identity not material)
- State v. Paris, 414 P.2d 512 (1966) (trustworthiness-modified corpus delicti approach)
- State v. Nance, 419 P.2d 242 (1966) (precedent on corpus delicti and independent evidence)
- State v. Downey, 195 P.3d 1244 (2008-NMSC-061) (gatekeeping for expert testimony)
- State v. Evans, 210 P.3d 216 (2009-NMSC-027) (voluntariness under totality of circumstances)
- State v. Vasquez, 232 P.3d 438 (2010-NMCA-041) (objective custody assessment for Miranda warnings)
- State v. Clifford, 873 P.2d 254 (1994) ( prohibition on using legal conclusions in expert testimony)