Triplett v. State, 65 Wis. 2d 365

Summary

The Supreme Court of Wisconsin affirmed a first-degree murder conviction, rejecting challenges to the voluntariness of the defendant's confession, the adequacy of the trial court's findings on admissibility, and the sufficiency of corroborating evidence. The court held that the confession was voluntary under the totality of the circumstances, that the trial court's findings were sufficient, and that significant facts corroborated the confession. The court also declined to reverse in the interest of justice.

Holdings

1. The trial court's determination that Triplett's oral statements and written confession were voluntary was not against the great weight and clear preponderance of the evidence, and the confession was properly admitted.
2. The trial court's oral finding that the statements and written confession were made freely and voluntarily without promises or coercion was an adequate and sufficient finding of fact, even though the court did not provide the promised supplemental memorandum.
3. The conviction was supported by sufficient evidence because Wisconsin law requires only some corroboration of a confession, and the record contained corroboration of multiple significant facts concerning the offense.
4. Reversal in the interest of justice was not warranted because the record did not show a probable miscarriage of justice or establish that Triplett should not have been found guilty and deserved a new trial.

Questions Presented

1. Whether the evidence was sufficient to support the trial court's finding that Triplett's oral statements and written confession were voluntary.
2. Whether the trial court made sufficient findings of fact and conclusions of law regarding the admissibility of the confession.
3. Whether the evidence, including corroboration of Triplett's confession, was sufficient to sustain his conviction for first-degree murder as a party to a crime.
4. Whether reversal in the interest of justice was warranted.

Disposition

affirmed