Coleman v. State
2013 Miss. LEXIS 561
| Miss. | 2013Background
- Patrick Coleman charged with murder; pretrial competency hearing was not held due to trial court conclusion of waiver.
- Coleman requested a competency evaluation under Rule 9.06; evaluation occurred but no timely pretrial hearing followed.
- Trial proceeded in June 2009 with a four-page summary mental health report indicating several disorders but concluding present ability to defend.
- A nunc pro tunc retrospective competency hearing was held in September 2011 after appellate remand.
- Trial court relied on the summary report and Coleman’s trial demeanor to conclude competence; full 29-page report was not admitted.
- Mississippi Supreme Court holds Rule 9.06 requires a separate competency hearing before trial after an evaluation; retrospective determinations do not satisfy the rule.
- Court reverses Court of Appeals and Lauderdale County Circuit Court; remands for new proceedings consistent with ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rule 9.06 compliance after evaluation | Coleman; failure to hold timely hearing violated Rule 9.06 | State; retrospective hearing may suffice if purposes of Rule 9.06 are met | Retrospective hearing does not satisfy Rule 9.06; new trial remanded |
| Effect of pretrial waiver finding | Coleman entitled to competency hearing before trial | Waiver prevented timely hearing | Error to deny timely competency hearing; remand for new trial |
| Appropriate remedy | Remand for new trial necessary to protect due process | Retrospective hearing adequate under some contexts | Remand for new trial; retrospective hearing insufficient |
Key Cases Cited
- Hearn v. State, 3 So.3d 722 (Miss. 2008) (pretrial hearing not strictly required if purposes of Rule 9.06 fulfilled)
- Sanders v. State, 9 So.3d 1132 (Miss. 2009) (mandatory post-examination competency hearing; reversal if not held)
- Jay v. State, 25 So.3d 257 (Miss. 2009) (pretrial competency hearing required)
- Pitchford v. State, 45 So.3d 216 (Miss. 2010) (retrospective hearing considered under certain conditions; notice required)
- Drope v. Missouri, 420 U.S. 162 (U.S. 1975) (due process in nunc pro tunc competency determinations)
- Pate v. Robinson, 383 U.S. 375 (U.S. 1966) (due process concerns in competency assessments)
- Dusky v. United States, 362 U.S. 402 (U.S. 1960) (standard for mental competency to stand trial)
- Illinois Central R. Co. v. Moore, 994 So.2d 723 (Miss. 2008) (enforces Rule 9.06 clear language; rule must be enforced)
- Box v. State, 437 So.2d 19 (Miss. 1983) (rule as authoritative directive for conduct)