Kuhlmann v. Wilson

477 U.S. 436 (1986)

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Nature of the Case

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Facts

Wilson (D) and two others robbed a garage and killed the night dispatcher. Four days later, D turned himself in. D claimed that he witnessed the robbery and murder but that he had nothing to do with them. D also described the robbers but denied knowing them. D was indicted for murder. In jail, D told his cellmate (a police informer) the same story. The informant did not elicit more information, but did say D's story 'didn't sound so good.” Several days later, D changed his story and told the informer that he and the others planned and carried out the robbery, killing the dispatcher. The informer reported these statements to the police, and these statements were used to convict D. The trial court denied D's motion to suppress the incriminating statements he made to the informant, finding D's statements spontaneous and unsolicited. D was convicted of murder. The federal district court denied D's habeas corpus petition. It found no interrogation by the informer and only spontaneous statements from D. The U.S. Court of Appeals affirmed. Following United States v. Henry, which applied the Massiah test to suppress statements made to a paid jailhouse informant, D decided to relitigate his Sixth Amendment claim. His motion to vacate his conviction was denied in state court and federal district court. The Court of Appeals reversed. The Supreme Court granted certiorari.