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Coddington v. State
Court of Criminal Appeals of Oklahoma · 2011-08-23 · cited 21×
In Coddington v. State, the Oklahoma Court of Criminal Appeals considered an application for post-conviction relief from James Coddington, who had been convicted by a jury of first-degree murder and sentenced to death. Coddington argued that his appellate counsel provided ineffective assistance by failing to investigate and raise claims about inaccurate voir dire responses from jurors in his first trial and other potential errors at trial and resentencing. The court denied relief, concluding that the claims either were or could have been raised in prior direct appeals and thus were waived or barred by res judicata, that Coddington did not demonstrate deficient performance by counsel under prevailing professional norms or resulting prejudice as required by Strickland v. Washington, and that the post-conviction process does not allow relitigation of issues already addressed. A separate concurring opinion reinforced the application of waiver doctrines and noted distinctions in evidentiary and Confrontation Clause issues.
criminal lawprocedure
State v. Mosley
Court of Criminal Appeals of Oklahoma · 2011-07-19 · cited 3×
In State v. Mosley, the defendant was charged with trafficking in methamphetamine and failure to display a tax stamp. During the first trial, a police officer testified about the defendant's prior arrests and probation status in violation of a motion in limine, prompting the defense to request and receive a mistrial. The trial court later granted the defendant's motion to dismiss the charges on double jeopardy grounds, finding that the State's negligence in failing to properly instruct the witness created manifest necessity for the mistrial and barred retrial. On appeal by the State, the court analyzed U.S. Supreme Court precedent requiring a showing that the prosecutor intentionally goaded the defense into requesting a mistrial to invoke double jeopardy protections, noting that mere negligence or reckless indifference does not suffice, and that the defendant's choice to seek a mistrial generally permits retrial absent such intent.
criminal lawprocedure
Coddington v. State
Court of Criminal Appeals of Oklahoma · 2011-05-13 · cited 38×
This case involves James Coddington's appeal of his death sentence following a resentencing trial for first-degree murder after he bludgeoned his friend Albert Hale with a hammer during a robbery and left him to die. The jury found four aggravating circumstances, including that the murder was heinous, atrocious, or cruel, and recommended the death penalty. On appeal, Coddington raised eighteen propositions of error, primarily challenging the removal of prospective jurors opposed to the death penalty without adequate rehabilitation and other issues such as evidentiary rulings and prosecutorial conduct. The Oklahoma Court of Criminal Appeals affirmed the sentence, holding that the trial court properly applied standards for excusing jurors whose views would substantially impair their duties, that no prejudice resulted from voir dire procedures, and that other claims lacked merit under established precedents.
criminal lawprocedure
Robinson v. State
Court of Criminal Appeals of Oklahoma · 2011-04-21 · cited 67×
In Robinson v. State, the defendant was convicted of first-degree murder and sentenced to life imprisonment after a jury trial in which he received fewer than the nine peremptory challenges required by Oklahoma statute. On appeal, Robinson argued that the denial of peremptory challenges constituted structural error requiring reversal under the court's prior precedent in Golden v. State. The Oklahoma Court of Criminal Appeals reexamined Golden in light of U.S. Supreme Court decisions such as Rivera v. Illinois and Ross v. Oklahoma, concluding that peremptory challenges are a statutory right rather than a constitutional one, so the erroneous denial is subject to harmless-error review rather than automatic reversal. Because the jury that convicted Robinson was fair and impartial with no members removable for cause, the court held the error harmless under state law and affirmed the conviction.
criminal lawprocedure
Webster v. State
Court of Criminal Appeals of Oklahoma · 2011-04-12 · cited 7×
The case involved Roderick Earsel Webster's jury trial and conviction for first-degree murder under Oklahoma law for the 1989 killing of Audrey Harris, resulting in a sentence of life imprisonment without parole. Webster appealed, raising issues including the admission of expert testimony on crime scene analysis and DNA evidence, the introduction of graphic photographs, prosecutorial comments, and discovery violations. The court reviewed the trial record, which included evidence such as palm prints, DNA matches, and witness accounts linking Webster to the scene, and addressed claims of error in the handling of expert opinions and evidence. It concluded that any procedural or evidentiary issues did not amount to reversible error under applicable standards, thereby affirming the conviction.
criminal lawprocedure
State v. Heath
Court of Criminal Appeals of Oklahoma · 2011-01-24
In State v. Heath, Nicole Heath was charged with first-degree robbery after she and a co-defendant allegedly followed an autistic victim from a mall arcade, offered him a ride, drove him to a secluded area, and robbed him of his fanny pack containing cash. The district court sustained Heath's motion to quash the information and dismissed the case, concluding the preliminary hearing evidence was insufficient to show she knew about or participated in the crime. On the State's appeal, the Oklahoma Court of Criminal Appeals reversed, holding that the victim's testimony about Heath driving the getaway car and other circumstances provided adequate probable cause to infer her knowledge and active role as a principal in the robbery. The court emphasized that circumstantial evidence can establish probable cause at the preliminary stage and that the State need not prove guilt with certainty at that point.
criminal lawprocedure