State of Louisiana v. Robert Glen Coleman
188 So. 3d 174
La.2016Background
- In 2003 Robert Glen Coleman was indicted for the first-degree murder of Julian Brandon and attempted murder of Alice Brandon; after a first trial (conviction and death sentence) this court vacated and remanded due to a Batson violation; a second trial in 2012 again produced a first-degree murder conviction and a unanimous death sentence.
- The State’s penalty-phase case included evidence of an unrelated 2003 homicide (Terrance Blaze) and expert bloodstain testimony tying Coleman to Blaze’s killing; the State had provided a Jackson notice but repeatedly represented the penalty evidence would mirror the first trial.
- Defense sought to admit numerous out‑of‑court statements by co-defendant Brandy Holmes (many varying and inconsistent) and other evidence bearing on third‑party guilt and shoe size; the trial court excluded much of that material and limited certain demonstrations at trial.
- Coleman moved to suppress statements and physical evidence obtained after officers brought him from a trailer to the sheriff’s office; the trial court found the interaction non‑custodial, consent to searches voluntary, and admitted the evidence.
- After conviction, Coleman raised 38 assignments of error on appeal; this opinion affirms the conviction but vacates the death sentence and remands for a new penalty hearing based on the State’s failure to provide adequate notice and its presentation of inconsistent and materially changed evidence regarding the Blaze homicide.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Coleman) | Held |
|---|---|---|---|
| Admissibility of Brandy Holmes’ out‑of‑court statements | Many of Brandy’s statements were used previously and are admissible under hearsay exceptions/Chambers due‑process principles | Statements were unreliable, inconsistent, and excluded in error, denying Coleman his right to present a defense | Exclusion proper: accomplice non‑self‑inculpatory parts inadmissible under La. C.E. art. 804(B)(3) and Williamson; no violation of right to present a defense. |
| Suppression of evidence and statements after removal to station | Evidence obtained with voluntary consent; not an arrest/detention; Miranda waivers valid | Detention was coercive; Coleman’s intellectual deficits and intoxication made consent involuntary | Trial court credited police testimony; consent and waiver found voluntary; suppression denied and affirmed. |
| Admission of other‑crimes evidence (Blaze homicide) in penalty phase and adequacy of Jackson notice | State provided Jackson notice and represented it would present the same evidence as at prior proceedings; bloodstain expert’s changed testimony was part of admissible penalty evidence | State changed theory and expert opinion without adequate new notice; Coleman lacked opportunity to prepare or rebut; presentation was prejudicial and inconsistent, violating due process | Reversed penalty: State’s switch in evidence/theory (expert now implicating Coleman as shooter) and inadequate notice prejudiced reliability of sentencing; death sentence vacated and new penalty hearing ordered. |
| Voir dire limits and challenges for cause on capital jurors | Court limited inquiry into fact‑specific responses about penalty aggravators to avoid prejudgment; jurors expressing predisposition were rehabilitated and allowed to serve | Defense needed fact‑specific voir dire (including on a second homicide) to reveal biases and to excuse for cause; several jurors should have been excused | No abuse of discretion: court properly restricted voir dire from soliciting commitments on specific evidence; challenges for cause were correctly denied based on totality of juror answers. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (prohibits race‑based peremptory challenges)
- Chambers v. Mississippi, 410 U.S. 284 (hearsay exclusion cannot abridge right to present a defense when statements bear sufficient indicia of reliability)
- Williamson v. United States, 512 U.S. 594 (limitations on admitting non‑self‑inculpatory portions of co‑defendant confessions under declarations‑against‑interest rule)
- Holmes v. South Carolina, 547 U.S. 319 (trial court may exclude defense evidence when its probative value is outweighed by countervailing considerations)
- State v. Prieur, 277 So.2d 126 (La.) (limits on other‑crimes evidence; relevancy standards)
- State v. Jackson, 608 So.2d 949 (La.) (Jackson notice and pretrial hearing required before admitting unadjudicated violent crimes at capital sentencing)
- Gregg v. Georgia, 428 U.S. 153 (death penalty jurisprudence requiring heightened reliability in capital sentencing)
- Rock v. Arkansas, 488 U.S. 44 (defendant’s constitutional right to testify; subject to reasonable procedural regulation)
- Mapp v. Ohio, 367 U.S. 643 (exclusionary rule for unlawful searches and seizures)