STATE OF NEW JERSEY VS. JAMES COLEMAN A/K/A IBN EL-AMIN Â PASHA(04-03-0255, MIDDLESEX COUNTY AND STATEWIDE), A-3938-15T1

James Coleman (aka Ibn El-Amin Pasha) was convicted after two trials for two 2003 murders and multiple related offenses (stalking, terrorizing), and sentenced to 168 years. His convictions were affirmed on direct appeal.
Coleman filed a post-conviction relief (PCR) petition asserting 25 trial-counsel errors and 7 appellate-counsel errors, including alleged failure to investigate, call witnesses, object to evidence, adequately cross-examine, communicate a plea, and seek severance.
The PCR court (Judge Mulvihill) denied relief without an evidentiary hearing and issued a detailed 53-page opinion analyzing the claims in the context of the State's evidence and trial strategy.
Coleman argued the PCR court erred by refusing an evidentiary hearing, that claims were not barred by R.3:22-5, and that he received ineffective assistance of counsel (trial and appellate).
The Appellate Division affirmed the PCR denial, applying Strickland standards and finding Coleman failed to show deficient performance or prejudice sufficient to overturn his convictions.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Coleman)	Held
Whether the PCR court erred by denying an evidentiary hearing	No error; record and judge's review sufficed	An evidentiary hearing was required to develop factual disputes about counsel's performance	Denial affirmed; judge's detailed review found no disputed material facts requiring a hearing
Whether claims are barred by R.3:22-5 (procedural default)	Some claims may be procedurally barred; however, PCR disposition addressed merits where appropriate	Claims were not barred and should be considered on their merits	Court effectively resolved claims on the merits; did not grant relief on procedural-bar grounds
Whether trial counsel was ineffective (multiple alleged failures)	Counsel's strategic choices were reasonable; isolated errors do not meet Strickland prejudice prong	Counsel failed to investigate, call witnesses, object, cross-examine, and communicate a plea offer, resulting in prejudice	Denied: counsel's performance fell within reasonable strategic judgment and Coleman failed to show prejudice under Strickland
Whether appellate counsel was ineffective	Appellate advocacy was adequate given record and issues selected	Appellate counsel neglected meritorious issues and rendered ineffective assistance	Denied: appellate counsel's performance not constitutionally deficient; no reversible prejudice shown

Strickland v. Washington, 466 U.S. 668 (1984) (two-pronged test requiring deficient performance and resulting prejudice for ineffective-assistance claims)
State v. Fritz, 105 N.J. 42 (1987) (adoption of Strickland standard in New Jersey)
State v. Castagna, 187 N.J. 293 (2006) (assessing counsel performance in context of overall defense and State's evidence)
State v. Allegro, 193 N.J. 352 (2008) (dissatisfaction with tactical choices does not automatically establish ineffective assistance)
State v. Harris, 181 N.J. 391 (2004) (applying Strickland to appellate counsel claims)
State v. Tacetta, 200 N.J. 183 (2009) (requirements concerning plea offers and factual basis)