Summary: A Psychology Expert Witness testified that because of defendant’s low IQ, he was not able to understand his Miranda Rights.
Facts: In State v. Bobby Willson 20020 IL App (1st) 162430 No. 1-16-2430 Filed March 26, 2020 Fourth Division, 16 year old Bobby Wilson was found guilty of first degree murder and sentenced to 37 years in prison.
The defendant appealed the case on the theory that (1) the trial court was in error by denying Wilson’s motion to suppress statements made to the police because he lacked the ability to fully understand his Miranda rights given by the police officer, (2) the State did not present enough evidence to prove his guilt based on its theory of accountability, (3) he was denied him a fair trial because of the trial court’s refused to give a jury instruction on the concept of “mere presence”, especially after the jury gave a question showing confusion on the law of accountability, (4) the defendant is entitled to a new sentencing hearing because the trial court failed to take into account mitigating factors for a 16 year old, and (5) his sentence was against the constitution.
During an alleged robbery in October 2012, the State alleges that the defendant shot and killed Kenton Morgan. Witnesses did not actually see the murder take place, but heard a struggle between in a van between three people and heard gunshots. Though the witness could not actually see any people inside the car, the car itself was shaking. The witness heard several gun shots, and a window shot out. Afterward, the witness saw a man exit the front driver’s side of the car and point a gun at him before running down the street. The witness then observed the decedent fall from the car and onto the sidewalk, where he eventually died. Then the defendant Bobby Wilson, exited the vehicle without a gun. The witness knew Wilson, and asked what took place. However, Wilson was hysterical and did not respond. He left the scene.
The police eventually arrested defendant. Before he was questioned, the defendant was read his Miranda rights, the defendant said he did not understand that an attorney would be appointed if he could not afford one. The detective explained what that meant. However, the detective did not inform the defendant that he could have an attorney present during his questioning. All of this was recorded on video, which was put into evidence.
At first he denied any involvement in the shooting. After more questions, Wilson admitted that he was at the scene but denied any role in the killing. During the interview, Wilson gave different accounts and contradictory statements about what occurred in the car.
The State argued in their closing argument that defendant worked together with another to rob the decedent by threatening him with a gun inside his car. When the decedent fought back, two shots were fire car, one of which killed the man. Afterwards, the State pointed out that defendant did not seek help for the victim, and did not explain to the witness what happened. The State argued that the evidence demonstrated that defendant went into victim’s car to rob him, and based on the law, when the victim died as a result of a planned robbery, the defendant was guilty of murder, even though he might have pulled the trigger.
The jury found Bobby Wilson guilty of first degree murder.
Discussion: Psychology Expert Witnesses on both sides presented conflicting evidence about the intellectual capacity of the 16 year old defendant. While the State’s Expert Witness found that he was capable of understanding his Miranda Rights, the Defendant’s Expert Witness cited his low IQ scores and scholastic record to point to his limited intellectual capacity. The appellate court ultimately found that his responses to the questions were not voluntary, and those statements should not have been admitted into evidence. It was clear that jury relied on those inadmissible statements, which was not a harmless error.
Conclusion: The appellate court found that the defendant Bobby Jenkins did not have the ability to understand his Miranda rights and therefore could not waive those rights, his statement made to the police should have been suppressed. Because a second trial would violate his rights under the 5th Amendment of the U.S. Constitution, the appellate court also reversed his conviction.