Coddington v. Sharp, 959 F.3d 947

In March 1997 Coddington, with a history of heavy cocaine use, committed multiple robberies; later the same day he attacked Al Hale with a claw hammer after Hale refused to lend him money; Hale died 24 hours later from blunt-force trauma.
Coddington took $525 from Hale, immediately bought more cocaine, committed additional robberies, discarded the hammer, and was arrested two days later.
At arrest Coddington made voluntary statements, was read Miranda warnings, waived them, and later at the station gave a detailed confession describing the attack and other robberies.
At trial the court admitted much expert testimony about cocaine’s effects but excluded Dr. Smith’s testimony opining that Coddington could not form malice aforethought; the court denied a motion to suppress the confession.
A jury convicted Coddington of first‑degree murder and robbery with a dangerous weapon; after an appellate remand and resentencing he was again sentenced to death; the OCCA found the exclusion of Dr. Smith’s opinion erroneous but harmless; Coddington’s § 2254 petition raised, inter alia, (1) that excluding the intent opinion violated his right to present a defense and (2) that his Miranda waiver was not knowing and voluntary.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exclusion of expert opinion that defendant could not form malice aforethought	Coddington: excluding Dr. Smith’s opinion deprived him of his right to present a defense and was not harmless because the opinion went to the ultimate issue of intent	State: such testimony on the ultimate issue is inadmissible under Rule 704 and, even if error, the record contained ample evidence of intent making any error harmless beyond a reasonable doubt	Court: assumed constitutional error but, applying AEDPA and Chapman/Brecht standards, affirmed that the OCCA reasonably concluded exclusion was harmless — no substantial and injurious effect on verdict
Miranda waiver: confession admissibility	Coddington: waiver was unknowing and involuntary due to officers’ misleading statements about subjects, a 2–3 hour gap between waivers, and his intoxication/sleep deprivation	State: officers reminded him of earlier waiver, he acknowledged it; prior encounters made him familiar with Miranda; intoxication did not rise to substantial impairment or overborne his will	Court: OCCA reasonably applied federal law; totality of circumstances shows waiver was knowing and voluntary and confession was admissible

Chapman v. California, 386 U.S. 18 (1967) (state must prove federal constitutional error harmless beyond a reasonable doubt)
Brecht v. Abrahamson, 507 U.S. 619 (1993) (collateral-review harmless‑error standard: substantial and injurious effect)
Davis v. Ayala, 135 S. Ct. 2187 (2015) (under AEDPA federal habeas relief unavailable unless state harmlessness determination was unreasonable)
Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings and waiver requirements)
Moran v. Burbine, 475 U.S. 412 (1986) (two dimensions of waiver inquiry: voluntariness and knowingness)
Colorado v. Spring, 479 U.S. 564 (1987) (suspect’s awareness of all possible subjects of questioning is irrelevant to waiver validity)
United States v. Burson, 531 F.3d 1254 (10th Cir. 2008) (mere drug use does not automatically make a waiver involuntary; must show substantial impairment or overborne will)