Lawrence Coleman v. Marcus Hardy
2012 U.S. App. LEXIS 16105
7th Cir.2012Background
- Coleman was convicted of first-degree murder in Illinois and sentenced to 28 years.
- Detective Graziano arrested Coleman on December 12, 2008, and interrogation yielded a confession by midnight.
- A court reporter recorded Coleman’s confession after Assistant State’s Attorney Nazarian joined in the interview.
- Coleman moved to suppress the confession, arguing Miranda rights were invoked; the suppression court credited State witnesses over Coleman.
- Illinois appellate court upheld the conviction, and Coleman pursued federal habeas relief under 28 U.S.C. § 2254.
- The district court denied relief; on appeal, the sole issue is whether Coleman’s statements were admissible after invoking the right to counsel under Edwards v. Arizona.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether waiver of counsel was valid under Edwards | Coleman argues Edwards required careful totality-of-circumstances review | State court properly applied Edwards and considered totality of circumstances | State court reasonably applied Edwards; no error under § 2254(d)(1) |
| Whether the state court’s review of waiver was unreasonable under AEDPA | Coleman claims the court’s language showed improper weighting of factors | Court weighed all relevant factors reasonably | No unreasonable application under § 2254(d)(1) |
| Whether the state court’s credibility findings were an unreasonable determination of facts | Affidavits post-conviction undermine trial court credibility rulings | Affidavits raised too late; credibility findings owed deference | Affidavits raised on appeal were waived; no § 2254(d)(2) error |
Key Cases Cited
- Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (right to counsel must be honored after invocation; waiver must be knowing and intelligent)
- Moran v. Burbine, 475 U.S. 412 (U.S. 1986) (waiver analyzed with awareness of rights and consequences)
- Fare v. Michael C., 442 U.S. 707 (U.S. 1979) (totality of circumstances governs understanding of waivers)
- North Carolina v. Butler, 416 U.S. 445 (U.S. 1974) (post-rights-waiver interaction controls admissibility)
- Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (unreasonable application when extending/refusing Supreme Court precedent)
- Harrington v. Richter, 131 S. Ct. 770 (S. Ct. 2011) (AEDPA deference to state-court factual determinations and law)
- Etherly v. Davis, 619 F.3d 654 (7th Cir. 2010) (weighing factors under totality of circumstances may vary; not clear error to differ)
- Rice v. Collins, 546 U.S. 333 (U.S. 2006) (credibility determinations are generally insulated from habeas relief)
- Miller-El v. Dretke, 545 U.S. 231 (U.S. 2005) (AEDPA standard for evaluating state-court factual and legal conclusions)
- McCarthy v. Pollard, 656 F.3d 478 (7th Cir. 2011) (recites AEDPA deference and standard for state-court findings)