Wilkerson v. State
47, 2024
| Del. | Jan 7, 2025Background
- Randon Wilkerson, a habitual drug user, engaged in a violent spree resulting in the killing of a police officer and assaults on others while under the influence of multiple illegal substances.
- Wilkerson claimed his intoxication was involuntary because the methamphetamine he believed he took was allegedly substituted with "bath salts" without his knowledge.
- At trial, Wilkerson sought to present an involuntary intoxication defense under Delaware law, but the Superior Court excluded the defense and related evidence as a matter of law.
- The Superior Court found Wilkerson’s conduct to be voluntary, precluding the involuntary intoxication defense, and also rejected his proffered expert reports as inadmissible under the evidentiary rules.
- Wilkerson was convicted on all counts after a stipulated-fact bench trial and received a sentence of two life terms plus 212 years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Availability of involuntary intoxication defense when illegal drug taken differs from what was intended | Section 423 allows the defense if the defendant was unaware of the drug's intoxicating nature | If a defendant knowingly takes an illegal drug, the defense is legally unavailable | Defense unavailable; knowingly ingesting an illegal drug bars the involuntary intoxication defense absent exceptions |
| Use of 1973 Commentary to interpret Section 423 | Commentary supports defense availability if the intoxicating nature was unknown | Statutory language is unambiguous and prevails over commentary | Plain, unambiguous statutory text controls; commentary cannot override statute if text is clear |
| Application of evidentiary standards to expert testimony and lay evidence supporting defense | Delaware Rules of Evidence, not Section 303, should decide admissibility | Rule 702 and Section 303 used properly to exclude non-credible and inadmissible evidence | Not resolved; Court finds the defense unavailable as a matter of law, making exclusion of evidence a moot issue |
| Whether exclusion of the defense/evidence violated due process | Precluding the defense at pre-trial stage denied right to a full defense | Preclusion legal due to statutory bar; no due process violation | No due process violation; defense legally unavailable so no right to present related evidence |
Key Cases Cited
- State v. Baker, 720 A.2d 1139 (Del. 1998) (sets de novo standard for questions of statutory interpretation)
- Richardson v. State, 673 A.2d 144 (Del. 1996) (distinguishes questions of law for statutory construction)
- Arnold v. State, 49 A.3d 1180 (Del. 2012) (emphasizes role of court to apply unambiguous statutory language)
- Garrison v. Red Clay Consol. Sch. Dist., 3 A.3d 264 (Del. 2010) (primary goal is to effectuate statutory intent through text)
- Friends of H. Fletcher Brown Mansion v. City of Wilmington, 34 A.3d 1055 (Del. 2011) (plain language controls interpretation absent ambiguity)