COLEMEN v. State
341 S.W.3d 221
| Tenn. | 2011Background
- Coleman killed Mr. Watson during a robbery in 1979; conviction for first-degree murder and death sentence upheld on direct appeal.
- Coleman pro se post-conviction petitions over the years challenged intellectual disability and trial counsel effectiveness.
- Court and post-conviction courts previously found Coleman failed to prove intellectual disability and that ineffective assistance claims were procedurally barred.
- Experts Baumeister and Woods testified Coleman’s intellectual disability affected adaptive functioning and could interrelate with mental illness.
- Tennessee Supreme Court vacated lower rulings, held §39-13-203(a)(1) permits evidence beyond raw IQ scores to establish functional I.Q. at time of offense and remanded for further proceedings on adaptive deficits.
- Court underscored the importance of clinical judgment in evaluating intellectual disability and remanded with guidance on admissibility of expert testimony and potential re-presentation of evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Interpretation of §39-13-203(a)(1) for functional I.Q. | Coleman argues only raw IQ scores should count. | State contends statutory framework allows only scores or tests. | Statute permits evidence beyond raw scores; functional I.Q. may be shown by qualified experts. |
| Deficits in adaptive behavior proof under §39-13-203(a)(2). | Coleman established adaptive deficits under DSM criteria. | Lower courts properly found no substantial adaptive deficits. | Remanded for further proceedings; error in excluding expert testimony and intertwining causes (intellectual disability and mental illness). |
| Effect of Howell v. State on due process for counsel-ineffectiveness claims. | Howell creates a due process right to merit review of such claims. | Howell does not revive barred claims or alter limitations. | Howell does not retroactively revive Coleman’s claims; procedural bars remain; remand for new evidentiary consideration on adaptive deficits. |
| Scope of expert testimony admissibility for I.Q. assessment. | Experts may testify on functional I.Q. without range limitations. | Testimony should be limited to explicit 70 or below or above 70 determinations. | Experts may testify with full consideration of all tests, provided testimony is specific (70 or below or above 70). |
Key Cases Cited
- State v. Smith, 893 S.W.2d 908 (Tenn. 1994) (deficits in adaptive behavior; statutory interpretation constraints)
- Van Tran v. State, 66 S.W.3d 790 (Tenn. 2001) (adopts DSM-based framework for intellectual disability; retroactivity)
- Howell v. State, 151 S.W.3d 452 (Tenn. 2005) (limits on I.Q. interpretation; supports clinical judgment guidance)
- State v. Strode, 232 S.W.3d 1 (Tenn. 2007) (interpretation of developmental period and adaptive deficits; procedural posture)