Coleman v. State
| Docket Number: | 2009-KA-01350-COA Linked Case(s): 2009-KA-01350-COA ; 2009-CT-01350-SCT ; 2009-CT-01350-SCT ; 2009-CT-01350-SCT |
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| Court of Appeals: |
Opinion Link Opinion Date: 05-15-2012 Opinion Author: Barnes, J. Holding: Affirmed |
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| Additional Case Information: |
Topic: Murder - Competency to stand trial - URCCC 9.06 - Ineffective assistance of counsel Judge(s) Concurring: Lee, C.J., Irving and Griffis, P.JJ., Ishee, Roberts, Carlton, Maxwell, Russell and Fair, JJ. 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: | On October 24, 2013, the Supreme Court found the competency hearing ordered by the Court of Appeals did not comply with the strict procedures mandated by Rule 9.06. It then reversed the judgments of the Court of Appeals and the circuit court and remanded the case to the trial court for new proceedings. | |
| Party Name: | Attorney Name: | Brief(s) Available: | ||
| Appellant: | Patrick Coleman |
ERIC JOHN HESSLER |
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| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL: LADONNA C. HOLLAND | ||
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| Topic: | Murder - Competency to stand trial - URCCC 9.06 - Ineffective assistance of counsel |
| Summary of the Facts: | Patrick Coleman was convicted of murder and sentenced to life in prison. He appeals. |
| Summary of Opinion Analysis: | Issue 1: Competency to stand trial Coleman argues that it was error for the trial court to fail to hold a hearing to determine whether Coleman was competent to stand trial under URCCC 9.06. The Court of Appeals ordered the trial court to perform a retrospective competency hearing, where the parties could call witnesses and present relevant evidence as to the issue of Coleman’s competency to stand trial in June 2009. At the hearing in September 2011, Coleman did not present any evidence to support his assertion that he was incompetent to stand trial. Nor did he call any lay or expert witnesses who could testify to his behavior around the time of his trial in June 2009. The trial court issued an order finding Coleman was competent to stand trial in June 2009. The trial court did not err in this regard. Issue 2: Ineffective assistance of counsel Coleman argues that his trial counsel was ineffective. He claims she lacked preparation, a trial strategy, and a theory of defense, which was especially apparent during the issuance of jury instructions. Coleman criticizes his trial counsel for not filing a motion in limine regarding his confession to law enforcement. The Court will reach the merits on an ineffective assistance claim only in instances where the record affirmatively shows ineffectiveness of constitutional dimensions, or the parties stipulate that the record is adequate to allow the appellate court to make the finding without consideration of the findings of fact of the trial judge. Since neither of these instances is present here, Coleman’s conviction is affirmed without prejudice to his ability to raise an ineffective assistance of counsel claim in a proceeding for post-conviction relief. |
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