State of Vermont v. Wade Willis

Summary

The Vermont Supreme Court affirmed a first-degree murder conviction of a sixteen-year-old who contested the denial of his motion to transfer the case to juvenile court, the admission of evidence obtained after he led police to the victim following a single question given without Miranda warnings, alleged plain errors in the waiver of the psychiatrist-patient privilege and in expert sanity testimony, and the participation of assistant judges in contested rulings. The Court held the trial court erred both in its jurisdictional analysis of the transfer motion and in deeming the defendant in custody, but found no reversible error: the transfer denial rested on independent reasonable bases without shown prejudice, and the suppression ruling was affirmed because the defendant was not 'in custody' under the newly clarified objective totality-of-the-circumstances test. The unpreserved claims failed under the plain-error rule, and assistant-judge participation implicated due process rather than subject matter jurisdiction.