Jared Levi Coleman v. State
440 S.W.3d 218
| Tex. App. | 2013Background
- Jared Levi Coleman was indicted for murder; he pleaded not guilty and was convicted; sentence: 30 years' confinement.
- Coleman gave two non-custodial recorded/written statements on Sept. 27, 2011 (the "September Statements") and a custodial recorded statement on Oct. 7, 2011 (the "October Statement").
- Coleman moved to suppress the September Statements, claiming police promised to "help" him or promised probation/no jail in exchange for a confession; he also argued the October Statement was fruit of the poisonous tree.
- At the suppression hearing, testimony conflicted: a friend testified the officer promised probation; the officer denied promising leniency and the video did not show a promise of probation; officer told Coleman he was not under arrest and could leave and indicated he would not be jailed that day.
- The trial court found no promise or improper inducement, ruled the September Statements voluntary, and denied suppression; because they were admissible, the October Statement was not excluded as fruit of the poisonous tree.
- Coleman sought to admit expert testimony by Dr. Michael Fuller that Coleman fit a profile susceptible to false confession; the trial court disallowed the opinion after a gatekeeping hearing because Coleman failed to prove the methodology reliably applied to that opinion.
Issues
| Issue | Plaintiff's Argument (Coleman) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether the trial court erred in denying suppression of statements allegedly procured by promise/inducement | Officer (through friend) promised probation/no jail in exchange for confession, so statements involuntary under Art. 38.21 | No positive promise of leniency was made by an authority; statements were voluntary and video shows no promise; friend’s testimony contradicted officer | Court affirmed: totality of circumstances showed no positive promise by an authority that would overbear will; Sept. statements voluntary; Oct. statement not fruit of poisonous tree |
| Whether exclusion of forensic psychiatrist’s opinion that Coleman fit a false‑confession profile violated right to present a defense | Dr. Fuller should be allowed to testify that Coleman’s psychological profile made him likely to give a false confession (vital to defense) | Proponent failed to satisfy gatekeeping reliability requirements (Nenno/Kelly); methodology not shown reliable or tied to literature/principles | Court affirmed: trial court did not abuse discretion; proponent failed to prove by clear and convincing evidence that the expert’s methodology reliably supported the proffered opinion; exclusion not reversible constitutional error |
Key Cases Cited
- Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (standard of review for suppression rulings and deference to trial court credibility findings)
- Martinez v. State, 127 S.W.3d 792 (Tex. Crim. App. 2004) (promise must be positive, from authority, and influential enough to induce false confession)
- Dykes v. State, 657 S.W.2d 796 (Tex. Crim. App. 1983) (general offers to "help" typically do not invalidate confessions)
- Kelly v. State, 824 S.W.2d 568 (Tex. Crim. App. 1992) (gatekeeping factors for scientific expert testimony)
- Nenno v. State, 970 S.W.2d 549 (Tex. Crim. App. 1998) (adapted, more flexible reliability inquiry for non‑laboratory social‑science expert testimony)
- Coble v. State, 330 S.W.3d 253 (Tex. Crim. App. 2010) (application of Kelly/Nenno gatekeeping and burden of proof for expert reliability)