Coleman v. State
434 Md. 320
| Md. | 2013Background
- Coleman was convicted of first-degree murder and conspiracy to commit first-degree murder for the death of Quatrina Johnson and sentenced to life without parole and life imprisonment, consecutively.
- Coleman filed a 2009 post-conviction petition alleging ineffective assistance of counsel; the circuit court denied relief without addressing the specific claim.
- The intermediate appellate court initially denied relief, granted reconsideration, and again denied relief for lack of prejudice; this Court granted certiorari to address prejudice from trial counsel’s failure to object to post-Miranda silence references.
- Detective Childs’s testimony repeatedly referenced Coleman’s post-Miranda silence (about 30 times); defense counsel did not object and Coleman did not testify.
- The Fifth Amendment and due process prohibit use of post-arrest, post-Miranda silence for impeachment; the Court assesses deficient performance and prejudice under Strickland.
- The Court reverses the Court of Special Appeals and remands for a new trial based on deficient performance and substantial prejudice from the silence references.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel's failure to object to post-Miranda silence references was deficient performance | Coleman | Coleman | Yes; failure was deficient under Strickland |
| Whether post-Miranda silence references were admissible or prejudicial | Coleman | State | Prejudicial; references violated rights and were improper |
| Whether there was substantial prejudice to Coleman requiring relief | Coleman | State | Yes; substantial possibility verdict differed without the errors |
| Whether remand for a new trial is appropriate | Coleman | State | Remand for a new trial ordered |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong test for ineffective assistance)
- Doyle v. Ohio, 426 U.S. 610 (U.S. 1976) (post-arrest silence cannot be used for impeachment)
- Grier v. State, 351 Md. 241 (Md. 1998) (post-arrestMiranda silence inadmissible; due process)
- Perry v. State, 357 Md. 37 (Md. 1999) (prejudice analysis when admissibility issues arise; suppression context)
- Mosley v. State, 378 Md. 548 (Md. 2003) (post-conviction review; standards for evaluating counsel performance)