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