Coleman v. State
946 N.E.2d 1160
| Ind. | 2011Background
- Coleman shot Dye and Jermaine Jackson during a confrontation at Coleman's studio in 2007.
- He was charged with Jermaine's murder and Dye's attempted murder, tried in February 2008.
- Jury acquitted on Jermaine's murder; could not reach a verdict on Dye's attempted murder; mistrial declared on that count.
- Retrial occurred; jury convicted Coleman of Dye's attempted murder and he was sentenced to 45 years.
- Appeals argued collateral estoppel, prosecutorial misconduct, evidentiary errors, and improper sentence review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Collateral estoppel precludes retrial? | State argues no binding issue decided in first trial forecloses retrial. | Coleman argues the self-defense finding on Jermaine forecloses Dye-related claims. | Collateral estoppel does not bar retrial. |
| Prosecutorial misconduct occurred? | Coleman contends prosecutor used or failed to correct inconsistent testimony. | State argues any inconsistencies were not false testimony and closing references were fair. | No prosecutorial misconduct established; no fundamental error. |
| Exclusion of Dye statement evidence | Statements by Dye should be admissible to show Coleman’s fear/self-defense relevance. | Statements were inadmissible hearsay or irrelevant to fear for Dye. | Exclusion harmless error; not reversible. |
| Admission of Jermaine-related statements | Jermaine's statements should show fear or state of mind relevant to self-defense. | Jermaine statements do not place Coleman in fear of Dye; inadmissible. | Excluded statements properly limited; no error. |
| Sentence review permissible? | Rule 7(B) allows review for appropriateness given the offense and offender. | Sentence is appropriate given the conduct and Coleman’s history. | Sentence affirmed. |
Key Cases Cited
- Ashe v. Swenson, 397 U.S. 436 (U.S. 1970) (collateral estoppel defined; ultimate fact cannot be relitigated)
- Yeager v. United States, U.S. (U.S. 2009) (exposure of issues from prior acquittal; standards for relitigation)
- Little v. State, 501 N.E.2d 412 (Ind. 1986) (collateral estoppel within double jeopardy context)
- Randolph v. State, 755 N.E.2d 572 (Ind. 2001) (self-defense elements and justification standards)
- Timberlake v. State, 690 N.E.2d 243 (Ind. 1997) (witness testimony conflicting; not perjury when inconsistent)
- Hare v. State, 467 N.E.2d 7 (Ind. 1984) (evidence of acquitted conduct admissible to show weight; not admissible to prove conduct)
- Lashbrook v. State, 762 N.E.2d 756 (Ind. 2002) (exclusion of evidence standard; harmless error analysis)
- Cooper v. State, 854 N.E.2d 831 (Ind. 2006) (prosecutorial misconduct; preservation and review standards)
- Benson v. State, 762 N.E.2d 748 (Ind. 2002) (fundamental error standard in prosecutorial conduct)
- Sigler v. State, 700 N.E.2d 809 (Ind. Ct. App. 1998) (false testimony and due process considerations)