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Jamie Lee Coker v. State
405 S.W.3d 356
| Tex. App. | 2013
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Background

  • Jamie L. Coker was convicted of intoxication manslaughter and three intoxication assault offenses from a February 15, 2005 collision.
  • By September 2005, Coker agreed to a negotiated plea, waived jury trial, judicially confessed, and stipulated intoxicated operation caused Sonya Coker’s death.
  • Coker absconded to Mexico before a September 2005 final hearing and remained at large until 2011.
  • In 2011 he was arrested in Mexico and returned; the trial court denied his motions to withdraw his waivers and stipulations.
  • Coker argued the waivers and stipulations were involuntary and that admitting State exhibits violated hearsay, Confrontation Clause, and Fifth Amendment rights; the trial court found against him.
  • The appellate court affirmed, holding the waivers and stipulations were valid and that withdrawal was properly denied and admissibility issues were resolved by the stipulations.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Was the trial court’s denial of withdrawal of jury trial waivers an abuse of discretion? Coker argues waivers were involuntary due to coercion and intoxication. State asserts waivers were knowing and voluntary. No abuse of discretion; waivers valid.
Were the stipulations of evidence effectively binding and thus preclude challenges to exhibits? Coker claims stipulations were coerced and should be withdrawable. State relies on stipulations to admit evidence. Stipulations effective; exhibits admissible via stipulations.
Did the State’s exhibits violate hearsay, Confrontation Clause, or Fifth Amendment rights? Coker objects to admissibility and confrontation. Stipulations cured admissibility concerns. Objections overruled due to stipulations.
Did coercive conduct by counsel render waivers involuntary? Coker contends attorney coercion invalidated waivers. Record shows waivers were voluntary and informed. Waivers voluntary; no coercion established.

Key Cases Cited

  • Hobbs v. State, 298 S.W.3d 193 (Tex. Crim. App. 2009) (requires knowing, intelligent waiver of jury trial on the record)
  • Taylor v. State, 255 S.W.3d 399 (Tex. App.—Texarkana 2008) (abuse of discretion standard for withdrawal of waivers)
  • Marquez v. State, 921 S.W.2d 217 (Tex. Crim. App. 1996) (abuse of discretion in denying withdrawal of waivers)
  • Montgomery v. State, 810 S.W.2d 372 (Tex. Crim. App. 1990) (guiding rules for withdrawal of waivers; discretion applies)
  • Butler v. State, 872 S.W.2d 227 (Tex. Crim. App. 1994) (credibility determinations at pretrial hearings; voluntariness findings hinge on record)
  • Brito Carrasco v. State, 154 S.W.3d 127 (Tex. Crim. App. 2005) (trial court may set aside a stipulation; voluntariness considerations)
Read the full case

Case Details

Case Name: Jamie Lee Coker v. State
Court Name: Court of Appeals of Texas
Date Published: Jun 19, 2013
Citation: 405 S.W.3d 356
Docket Number: 06-12-00084-CR
Court Abbreviation: Tex. App.