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Coleman v. State

Supreme Court of Mississippi, En Banc

October 24, 2013

STATE of Mississippi.

Page 162

Patrick Coleman, pro se.

Office of the Attorney General by Ladonna C. Holland, Scott Stuart, attorneys for appellee.

KITCHENS, Justice.

¶ 1. The motion for rehearing is granted. The original opinions are withdrawn, and these opinions are substituted therefor.

¶ 2. More than two years after his trial, Patrick Coleman was ordered to a retrospective mental competency hearing by the Court of Appeals because he erroneously had been denied a pretrial competency hearing by the Lauderdale County Circuit Court. Finding tat the nunc pro tunc competency hearing did not adequately protect Coleman's due process rights and the procedural guarantees of Uniform Rule of Circuit and County Court Practice 9.06, we reverse the decisions of the Court of Appeals and the Lauderdale County Circuit Court and remand the case to the latter court for a new trial consistent with this decision.


¶ 3. The facts surrounding the death of Frederick Pruitt are gleaned from the record. The testimony of Kimberly Watts provides the following account of relevant events. On November 28, 2007, Patrick Coleman approached Watts's apartment. A number of Watts's friends, including Frederick Pruitt, were inside the apartment, preparing to play dominos. According to Watts, she saw Coleman and another man, both armed, running toward the house. Coleman demanded that Pruitt come out of the apartment. Watts testified that, when Pruitt refused to come out, Coleman entered the apartment and shot at Pruitt. A bullet struck Pruitt in the forehead and killed him. Watts stated that Coleman told her to call 911 and then waited outside the apartment for police to arrive.

¶ 4. Before trial, on November 24, 2008, Coleman filed a " Motion for Psychiatric Examination and/or Treatment." The trial court granted the motion in an effort to determine whether Coleman was mentally competent to stand trial and to ascertain his mental state at the time Pruitt was killed. The trial was continued several times while Coleman awaited his examination. The trial court granted a final continuance on March 24, 2009, setting the trial for June 1, 2009. At the time of the final continuance and scheduling of the trial for a day certain, no mental evaluation had been performed.

¶ 5. Coleman's psychological and psychiatric evaluation occurred on April 1, 2009, at the Mississippi State Hospital at Whitfield. The interview took approximately two hours. It was conducted by two state psychologists and a state psychiatrist, who prepared for it by reviewing Coleman's police records, his statement to police following his arrest, his psychiatric records from previous mental health treatment at three different hospitals, his school records, and information obtained from the jail staff where he was incarcerated. A four-page summary report of Coleman's evaluation was filed with the circuit court on May 18, 2009, two weeks before his

Page 163

scheduled trial. It noted that Coleman had been diagnosed with several psychiatric disorders, including schizophrenia, depression, intermittent explosive disorder, and personality disorder. He also had suffered from " alcohol abuse and cannabis abuse disorders." However, the report concluded that Coleman possessed " the sufficient present ability to consult with his attorney to a reasonable degree of rational understanding in the preparation of his defense, and that he had a rational as well as a factual understanding of the nature and object of the legal proceedings against him." The evaluators also determined that, at the time of the crime, " Coleman was not experiencing symptoms of a major mental illness."

¶ 6. Coleman's trial commenced on June 1, 2009. At that time, the summary report was the only information regarding the evaluation that had been received by the trial court and the attorneys for the prosecution and the defense. The following is taken from the Court of Appeals opinion in Coleman v. State, 127 So.3d 236, 237 (Miss.2012).

On the morning of June 1, 2009, Coleman's counsel ... requested a continuance, asserting that Coleman was entitled to a full competency hearing and that she needed time to subpoena witnesses who would testify as to Coleman's competency. She also wanted to cross-examine the physician who made the mental-evaluation report on Coleman. In response, the trial judge questioned why defense counsel had waited until the morning of trial after the jury had been qualified to request a competency hearing, when the defense had received the mental-evaluation report approximately ten days prior to trial. The trial judge concluded that the issue was waived....
On the second morning of trial, defense counsel again raised the issue of competency. She filed a motion for a mistrial and a reinstatement of the request for a competency hearing pursuant to Uniform Rule of Circuit and County Court 9.06, but the motion was denied. Attached to the motion was an affidavit from Coleman's wife stating that her husband " suffers from many mental problems," and before the incident, he " had been seeing invisible people and talking to himself for over a week" ; he " was out of his medication and was becoming more and more uncontrollable." Also attached was an affidavit by defense counsel insisting that Coleman was incompetent to stand trial.

Coleman testified in his own defense, stating that he meant only to scare Pruitt and not to shoot him, and that he blanked out before the second shot was fired. The trial court denied a jury instruction on the lesser-included offense of manslaughter. Coleman was convicted of deliberate design murder and sentenced to life in prison. After the trial, in a motion for new trial or judgment notwithstanding the verdict (JNOV), counsel for Coleman again argued that Rule 9.06 required a competency hearing that Coleman erroneously had been denied.

At the hearing on the post-trial motion, defense counsel ... introduced into evidence Coleman's full mental evaluation from Whitfield, which Coleman's attorney had only obtained the day before. Defense counsel explained that she had not requested a competency hearing before trial because it was her understanding that once the court orders the defendant to submit to a psychiatric examination under Rule 9.06, the court must conduct a hearing. The trial court ...

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