Wilson v. United States

Summary

The District of Columbia Court of Appeals reviewed Steven Wilson’s convictions for conspiracy to commit burglary, unarmed kidnapping, unarmed first-degree burglary, assault with a dangerous weapon, threat to kidnap or injure, and unlawful entry. Wilson challenged the sufficiency of the evidence, the denial of a claim-of-right jury instruction, the admission of prior consistent statements and text messages, and the merger of his unlawful-entry conviction with burglary. The court affirmed in part and vacated in part.

Holdings

1. The evidence was sufficient to support Wilson's conspiracy conviction because a rational jury could infer an agreement to enter Henderson's apartment with intent to assault or steal.
2. The evidence was sufficient to support Wilson's burglary conviction because the jury could find that he intended to assault or steal when he entered Henderson's apartment.
3. The court assumed without deciding that the requested claim-of-right instruction could be legally available to a defendant assisting a third party, but held that any failure to give the instruction was harmless.
4. The trial court did not abuse its discretion by admitting Henderson's statements to police and medical personnel because they were admissible to rebut an alleged recent fabrication or improper motive and to clarify purported inconsistencies raised on cross-examination.
5. The trial court did not abuse its discretion by admitting Ahmed's December 17, 2016, text message because it was relevant contextual evidence of the deteriorating relationship between Ahmed and Henderson and was not unfairly prejudicial.

Questions Presented

1. Whether sufficient evidence supported Wilson's convictions for conspiracy to commit burglary and first-degree burglary.
2. Whether the trial court erred by refusing to give a claim-of-right jury instruction on the burglary charge.
3. Whether the trial court abused its discretion by admitting Henderson's prior consistent statements to police and Ahmed's text message to Henderson.
4. Whether Wilson's unlawful-entry conviction merged with his burglary conviction.