Wilson v. Commonwealth

Summary

The Supreme Court of Kentucky affirmed Demetrius Maurice Wilson's murder conviction and twenty-one-year sentence. The court held that Wilson could not anticipatorily invoke Miranda rights before custody and that his statements after arrest were admissible. It also held that evidence of Wilson's marijuana possession was admissible under KRE 404(b) to establish motive and intent.

Holdings

1. Miranda rights attach only after a defendant is in custody and subjected to interrogation; an attempted invocation before custodial interrogation is premature and ineffective.
2. The trial court properly admitted evidence that Wilson possessed marijuana because the evidence was relevant to the Commonwealth's theory that the shooting arose from a drug deal gone bad and was probative of motive and intent, with probative value substantially outweighing unfair prejudice.

Questions Presented

1. Whether Wilson's pre-arrest statement that police should contact his attorney constituted a valid invocation of his Fifth Amendment rights under Miranda and required suppression of his subsequent post-arrest statements.
2. Whether the trial court erred under KRE 404(b) by admitting evidence that Wilson possessed marijuana on the night of the shooting.

Disposition

affirmed