A man convicted of criminal sexual conduct after he confessed while mentally ill to molesting his 1-year-old son will be granted a new trial, although his statement to police remains legitimate, according to the Minnesota Court of Appeals.
In an unpublished opinion Tuesday, a divided court ruled that Kirk R. Williams should again be allowed to stand trial for second-degree criminal sexual conduct because a Martin County district judge violated Williams' rights by excluding testimony from Williams' sister that he had never molested her, despite a confession that he had done so.
However, the confession that Williams made to an Iowa police investigator that he molested his son may stand because he waived his right to remain silent, even though he was hospitalized for mental illness.
According to the opinion, Williams was taken to the Ellsworth Mental Hospital in Iowa Falls after he became suicidal, depressed and delusional. Doctors later diagnosed schizophrenia.
While in the hospital, Williams told staff members that he had molested his son earlier that year and a sister at an earlier age. Staff members called police, who interviewed Williams after he had been taking medication. He signed a form waiving his Miranda rights and admitted to molesting his son while he was living with the boy's mother in Grenada, Minn. Five days later, he denied molesting his son or others, and was eventually released from the hospital.
He was eventually charged with second-degree criminal sexual conduct in Martin County. A judge refused to throw out his confession and did not allow his sister to testify that he had not molested her. A jury convicted him largely on testimony from the Iowa police officer who interviewed Williams, as well as the boy's mother, who testified that while she didn't notice bruises or marks on the boy, he had become clingy at the time of the incident. Williams appealed.
According to the opinion, Judge Kevin Ross wrote that prosecutors proved Williams' mental illness did not prevent him from understanding his rights when he waived them and that the police officer waited until hospital professionals said Williams was well enough to be interviewed. However, the district judge erred when he excluded the testimony from Williams' sister. Because he confessed to molesting her at the same time he admitted to molesting his son, the evidence is deemed relevant and should have been used in his defense. As a result, he should be granted a new trial.
Appeals Court Judge Thomas Kalitowski argued that the District Court's ruling should have been upheld. Testimony by Williams' sister that he did not molest her would have created "a trial within a trial" and confused the jury because Williams was not charged with abusing his sister. Judge David Minge argued that the entire conviction should have been reversed without consideration for a new trial because a person cannot be charged based on a confession alone. The testimony by the child's mother does not constitute evidence that a crime occurred. Additionally, a confession made, regardless of a Miranda waiver, should not be reliable if the statement comes from someone locked in a psychiatric ward for mental illness.
