State v. Wilds

In State v. Wilds, 133 N.C. App. 195, 515 S.E.2d 466 (1999), the defendant Curtis Wilds was accused of the first-degree murder of his wife, Tonya Wilds (Tonya). At trial, the State offered testimony from multiple witnesses regarding statements made by Tonya within a few weeks before her murder. Wilds, 133 N.C. App. at 203-04, 515 S.E.2d at 473-74. Testimony offered by the witnesses included the following statements by Tonya: (1) her husband had attempted to change her life insurance policy to designate himself as the named beneficiary; (2) she had once woken up in her bed during the night to discover her husband pouring gasoline on her nightgown; (3) she had an unhappy marriage filled with physical and emotional abuse; (4) she was afraid her husband would try to kill her. Id. Many of the witnesses specifically testified that Tonya was shaking and tearful when she made such statements. Id. The Wilds Court stated: Although statements that relate only factual events do not fall within the Rule 803(3) exception, statements relating factual events which tend to show the victim's state of mind, emotion, sensation, or physical condition when the victim made the statements are not excluded if the facts related by the victim serve to demonstrate the basis for the victim's state of mind, emotions, sensations, or physical condition. Wilds, 133 N.C. App. at 204-05, 515 S.E.2d at 474. The Court in Wilds therefore held that the statements were admissible to show Tonya's state of mind, despite the fact that the statements also contained descriptions of factual events. Id. at 205, 515 S.E.2d at 475.