315 A.3d 698
Me.2024Background
- Jaquille J. Coleman was convicted by a jury of murder and sentenced to 47 years for killing his ex-partner, Natasha Morgan, after she ended their relationship.
- The shooting occurred in August 2020, in front of Natasha’s mother at her home, with Coleman fleeing the scene and later being apprehended in Mississippi.
- At trial, the State introduced evidence that Natasha feared Coleman, including her use of a safe word with friends indicating concern for her safety.
- Defense argued an alternate suspect (Emily Staples) may have been the shooter, though no evidence directly supported this theory.
- During sentencing, Coleman allocuted but did not express remorse, instead distancing himself from responsibility for the murder.
- Coleman appealed conviction and sentence, challenging evidentiary rulings, prosecution comments in closing, and the consideration of his lack of remorse during sentencing.
Issues
| Issue | Coleman's Argument | State's Argument | Held |
|---|---|---|---|
| Admissibility of victim’s fear (state of mind) statements | Such statements were unfairly prejudicial and should be excluded under recent precedent. | Evidence was relevant to show Coleman's motive to kill. | Admissible as relevant to motive; no abuse of discretion. |
| Prosecutor’s burden-shifting closing remarks | Prosecutor impermissibly shifted burden to defense. | Remark was fair comment on lack of evidence of another shooter; context/curative instructions matter. | No error; comment responded to defense claims, jury properly instructed. |
| Cumulative error | Even if individually non-prejudicial, errors together warrant a new trial. | No error or, at most, harmless error given strength of evidence. | No cumulative error; conviction stands. |
| Sentencing: consideration of lack of remorse in allocution | Consideration of allocution violated Fifth Amendment self-incrimination right. | Voluntary allocution waives privilege; content may be considered. | No constitutional violation; allocution content was properly considered. |
Key Cases Cited
- State v. Penley, 288 A.3d 1183 (Me. 2023) (addressing exclusion of a victim’s state of mind, burden-shifting remarks by prosecution)
- State v. Fay, 130 A.3d 364 (Me. 2015) (evidence review standard following a conviction)
- State v. Cheney, 55 A.3d 473 (Me. 2012) (improper prosecutorial comments and harmless error analysis)
- State v. Roberts, 641 A.2d 177 (Me. 1994) (lack of remorse as a sentencing aggravating factor)
- State v. Berube, 698 A.2d 509 (Me. 1997) (affirming consideration of remorse in sentencing)
