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: 10-24-2013 Opinion Author: Kitchens, J. Holding: Reversed and Remanded |
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| Court of Appeals: |
Opinion Link Opinion Date: 05-12-2012 Opinion Author: Barnes, J. Holding: Affirmed |
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| Additional Case Information: |
Topic: Murder - Determination of mental competency - URCCC 9.06 - Pretrial mental competency hearing - Due process Judge(s) Concurring: Lamar, Chandler and King, JJ. Dissenting Author : Coleman, J. Dissent Joined By : Waller, C.J., Randolph, P.J., and Pierce, J Concurs in Result Only: Dickinson, P.J. Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY Writ of Certiorari: Granted Appealed from Court of Appeals |
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| Trial Court: |
Date of Trial Judgment: 06-02-2009 Appealed from: Lauderdale County Circuit Court Judge: Lester F. Williamson Disposition: CONVICTED OF MURDER AND SENTENCED TO LIFE IN THE CUSTODY OF THE MISSISSIPPI DEPARTMENT OF CORRECTIONS District Attorney: Bilbo Mitchell Case Number: 173-08 |
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| Note: | The motion for rehearing is granted. The original opinions are withdrawn, and these opinions are substituted therefor. Reversed and Remanded. The Supreme Court found that The retrospective competency hearing ordered by the Court of Appeals did not comply with the strict procedures mandated by Rule 9.06, and it we reversed the judgments of the Court of Appeals and the circuit court and remanded the case to the trial court. | |
| 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 - Determination of mental competency - URCCC 9.06 - Pretrial mental competency hearing - Due process |
| Summary of the Facts: | The motion for rehearing is granted, and these opinions are substituted for the original opinions. 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 which governs the procedure for a determination of mental competency in Mississippi, mandates a competency hearing after a psychiatric evaluation is conducted. However, in Hearn v. State, 3 So. 3d 722, 730 (Miss. 2008), the Court held that a hearing does not necessarily have to take place as long as the purposes of Rule 9.06 are satisfied. In two later cases, the Court held that the requirements of Rule 9.06 were not met when trial courts failed to conduct pretrial mental competency hearings. In this case, the State argues that since 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, the purposes of Rule 9.06 were satisfied, and, therefore, a new trial is not warranted. 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. Rule 9.06 is meant to ensure that a defendant’s due process rights are not violated, and its language is clear and simple. When a motion for a mental examination has been granted, such an examination must occur, and then a separate competency hearing must be conducted before trial begins. To proceed differently would not satisfy the purposes of Rule 9.06. It is neither prudent nor permissible for our trial courts, in their implementation of Rule 9.06, to deny a timely hearing on the accused person’s mental competence to stand trial, to proceed to trial, and then attempt later to remediate the omission by conducting an extremely untimely mental competency hearing. |
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