Coleman v. State

Citations: 127 So. 3d 236; 2012 Miss. App. LEXIS 277; 2012 WL 1674292Docket: No. 2009-KA-01350-COA

Court: Court of Appeals of Mississippi; May 15, 2012; Mississippi; State Appellate Court

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Patrick Coleman was convicted of murder and sentenced to life imprisonment. He appealed on two grounds: the trial court's failure to conduct a competency hearing before trial and ineffective assistance of counsel. The court found that under Uniform Rule of Circuit and County Court 9.06, Coleman was entitled to a competency hearing, which was subsequently held retroactively. The trial court determined Coleman was competent to stand trial, and the appellate court found no reversible error, affirming his conviction and sentence.

On November 28, 2007, Coleman confronted the victim, Frederick Pruitt, at Kimberly Watts's apartment, believing Pruitt had disrespected his wife. After demanding Pruitt exit the apartment, Coleman entered and shot Pruitt, killing him. Coleman admitted to shooting Pruitt in a voluntary statement to police. 

Defense counsel filed a motion for a psychiatric evaluation in November 2008, which was granted to assess Coleman’s understanding of the legal proceedings and his mental state at the time of the crime. Several continuances were granted for the evaluation, with a final continuance noted by the trial court, warning that failure of defense counsel to appear on the trial date would be treated as direct criminal contempt.

On April 1, 2009, a psychological evaluation of Coleman was conducted at Whitfield, with a report submitted to the trial court on May 18, 2009, signed by two psychologists and a psychiatrist. The evaluators reviewed Coleman’s police, psychiatric, and school records, interviewed him for two hours, and administered two hours of psychological testing. The report detailed Coleman’s extensive psychiatric history, including schizophrenia, depression, and explosive disorder, along with previous diagnoses of personality and substance abuse disorders. Despite this history, the evaluators concluded that Coleman was competent to stand trial, stating he could consult with his attorney and understood the legal proceedings against him. They noted no evidence that his mental illness impaired his awareness of the nature or wrongfulness of his actions at the time of the alleged offense, and he showed no active symptoms of psychosis during evaluation.

On June 1, 2009, Coleman’s attorney arrived late to court, requesting a continuance for a competency hearing and to subpoena witnesses. The trial judge questioned the timing of this request, given the defense had received the evaluation report ten days earlier, and deemed the issue waived, denying the continuance. Coleman's trial proceeded.

On the second day, defense counsel moved for a mistrial and reinstatement of the competency hearing, supported by affidavits from Coleman’s wife and herself, asserting Coleman’s mental instability and incompetence. The court denied this motion, and the notice of insanity defense filed by the counsel was also denied as untimely. During the trial, Coleman initially chose not to testify, later deciding to do so, despite his attorney’s ongoing concerns regarding his competency.

Coleman testified that on November 28, 2007, Pruitt initiated an argument, and although Coleman did not intend to shoot him, he fired the gun, believing Pruitt was reaching for a weapon (which was not found). Coleman described a loss of control, leading to a second shot that killed Pruitt. The jury received instructions on deliberate-design murder but not on manslaughter or self-defense, resulting in a guilty murder verdict and a life sentence for Coleman. In a subsequent motion for a new trial or judgment notwithstanding the verdict (JNOV), defense counsel argued the trial court violated Rule 9.06 by not conducting an on-the-record competency hearing, asserting that the mental evaluation summary provided was inadequate. At the hearing for the post-trial motion, defense counsel presented a full mental evaluation obtained shortly before the hearing but did not have new testimony. The trial court rejected the defense's arguments, asserting Coleman was competent to stand trial, and denied the motion. Coleman appealed, now represented by a different attorney. On appeal, Coleman contended that the trial court erred by failing to hold a competency hearing as required by Rule 9.06, citing *Sanders v. State*. The State countered that the trial court had made a competency determination based on the mental examination results, distinguishing it from *Sanders*. Alternatively, the State suggested a remand for a retrospective competency hearing if the court found an error. The appellate court agreed with the State's suggestion and ordered a retrospective competency hearing to assess Coleman's competency as of June 2009.

Coleman did not provide evidence at the September 2011 hearing to support his claim of incompetence to stand trial, nor did he call witnesses regarding his behavior during his June 2009 trial. The trial court determined that he was competent to stand trial, a decision supported by Coleman’s demeanor, his choice to testify, his testimony, the record, and counsel's arguments. The only issue remaining on appeal was Coleman's claim of ineffective assistance of counsel. Coleman alleged that his trial counsel was unprepared, lacked a trial strategy, and failed to request a jury instruction on manslaughter or challenge the admissibility of his confession. He argued these shortcomings prejudiced his case, leading to a murder conviction.

The court clarified that ineffective assistance claims raised on direct appeal should generally be denied without prejudice, allowing the defendant to raise them in a post-conviction relief proceeding. The court will only address the merits if the record clearly shows constitutional ineffectiveness or if both parties agree the record is sufficient for a decision. Neither condition was met in this case. Most of Coleman's claims involved trial counsel's alleged inaction, necessitating information beyond the record. Consequently, Coleman's conviction was affirmed, preserving his right to later assert ineffective assistance of counsel. Additionally, a thirty-page psychiatric report, which was not initially part of the appeal record and had not been reviewed by the trial court, confirmed Coleman’s long-standing mental health issues. Mississippi Rule 9.06 details the procedure for determining a defendant's competency to stand trial, and Coleman did not submit a reply brief to respond to the court's observations.