Coleman v. State
| Docket Number: | 2009-CT-01350-SCT Linked Case(s): 2009-KA-01350-COA ; 2009-KA-01350-COA ; 2009-CT-01350-SCT ; 2009-CT-01350-SCT |
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| Supreme Court: | Opinion Link Opinion Date: 06-20-2013 Opinion Author: Kitchens, J. Holding: Reversed and Remanded |
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| Additional Case Information: |
Topic: Murder - Retrospective competency hearing - URCCC 9.06 - Psychiatric evaluation - Due process Judge(s) Concurring: Dickinson and Randolph, P.JJ., Lamar, Chandler and King, JJ. Dissenting Author : Waller, C.J. Dissenting Author : Coleman, J. Dissent Joined By : Waller, C.J., and Pierce, J. |
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| Trial Court: |
Date of Trial Judgment: 06-02-2009 Appealed from: Lauderdale County Circuit Court Judge: Lester Williamson, Jr. |
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| Note: | On October 24, 2013, on motion for rehearing, the Supreme Court subsituted a new opinion for this one. The subsequent opinion can be found at http://courts.ms.gov/Images/Opinions/CO84852.pdf | |
| Party Name: | Attorney Name: | Brief(s) Available: | ||
| Appellant: | Patrick Coleman |
PRO SE |
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| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL: LADONNA C. HOLLAND SCOTT STUART |
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Synopsis provided by:  If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
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| Topic: | Murder - Retrospective competency hearing - URCCC 9.06 - Psychiatric evaluation - Due process |
| Summary of the Facts: | Patrick Coleman was convicted of deliberate design murder and sentenced to life in prison. On appeal, the Court of Appeals found that Coleman had been entitled to a competency hearing pursuant to URCCC 9.06. However, rather than reversing and remanding for a new trial, the Court of Appeals determined that there was “sufficient evidence to make a meaningful retrospective competency determination.” A retrospective competency hearing was held in the trial court, at which the parties were permitted to present evidence regarding Coleman’s competency to stand trial, or his lack thereof. The trial court found that Coleman had been mentally competent to stand trial. The Court of Appeals found no error and affirmed that determination. Coleman also raised an ineffective assistance of counsel claim on appeal, but the Court of Appeals declined to address it. The Supreme Court granted certiorari. |
| Summary of Opinion Analysis: | URCCC 9.06 mandates a competency hearing after a psychiatric evaluation is conducted. Coleman argues that the failure to reverse and remand for a new trial was error because Rule 9.06 mandates a competency hearing before trial if a motion for mental examination has been granted. The State argues that the purposes of Rule 9.06 were satisfied, because the post-trial, post-appeal competency hearing for Coleman was conducted on the basis of the mental evaluation Coleman had received before his trial occurred, and the information was current when Coleman went to trial, and Coleman was provided an opportunity to call witnesses and present evidence to support his position, as well as cross-examine the State’s witnesses. Rule 9.06 is meant to ensure that a defendant’s due process rights are not violated. It provides that, if the court has reasonable grounds to believe that the defendant is incompetent to stand trial, a mental evaluation shall be performed, and then a hearing shall be conducted to determine whether he is mentally fit to stand trial. To proceed differently would not satisfy the purposes of Rule 9.06. A retrospective competency hearing is not mentioned or even suggested by Rule 9.06, for the rule clearly specifies that a competency determination must occur “before or during trial,” not after trial, conviction, and appeal. |
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