Wilkes v. United States

Thomas Wilkes (defendant) began stalking Johnetta McLean after their romantic relationship soured. Ultimately, Wilkes ran McLean’s car off the road and fired at least seven shots at McLean and her coworker, Michelle Williams, as the women were trapped in McLean’s car. McLean died, and Williams was permanently paralyzed. The day after the crime, police obtained a warrant and arrested Wilkes. Wilkes made several incriminating statements without proper advisement or waiver of his Miranda rights, including disclosing where he discarded the gun and repeatedly saying “I did it.” The trial court determined that Wilkes’s statements, although voluntarily given, violated Miranda. Thus, the government (plaintiff) could not introduce the statements in its case-in-chief but could introduce the statements if Wilkes testified inconsistently with them. Wilkes presented an insanity defense through an expert witness, psychiatrist Dr. Saiger. Saiger testified that Wilkes had a dissociative disorder preventing Wilkes from controlling his behavior or realizing the implications of his actions. The prosecution impeached Saiger by asking whether his opinion would change had he known that Wilkes remembered what happened a day after the crime; Saiger admitted that the diagnosis was based largely on Wilkes’s claim that he had no memory of the shootings. The prosecution presented rebuttal witnesses, including police personnel who described Wilkes’s incriminating statements, and three experts who opined that, based in part on these statements, Wilkes was not legally insane during this crime. The trial court repeatedly cautioned the jury that Wilkes’s statements were admitted solely for the jury to determine how to weigh the experts’ opinions. The jury convicted Wilkes of armed second-degree murder and other offenses. Wilkes appealed, claiming that the introduction of his illegally obtained statements violated his Fifth Amendment privilege against self-incrimination.