Draft:Coleman v. Alabama

Coleman v. Alabama, 399 U.S. 1 (1970), was a criminal procedure case decided by the United States Supreme Court in 1970.

"Petitioners were convicted of assault with intent to murder and the Alabama Court of Appeals affirmed. They argue that (1) the in-court identifications that were made of them were fatally tainted by a prejudicial station house lineup (which occurred prior to United States v. Wade, 388 U. S. 218, and Gilbert v. California, 388 U. S. 263, requiring the exclusion of such tainted in-court identification evidence), and (2) that Alabama's failure to provide them with appointed counsel at the preliminary hearing, a "critical stage" of the prosecution, unconstitutionally denied them the assistance of counsel. The victim testified that, "in the car lights," while "looking straight at him," he saw the petitioner who shot him, and saw the other petitioner "face to face." He also stated that he identified the gunman at the station house before the formal lineup began, and identified the other before he spoke the words used by the assailants. The sole purposes of a preliminary hearing under Alabama law are to determine whether there is sufficient evidence to warrant presenting the case to a grand jury, and to fix bail for bailable offenses. The trial court scrupulously followed Pointer v. Texas, 380 U. S. 400, which prohibits the use of testimony given at a pretrial proceeding where the accused did not have the benefit of cross-examination by and through counsel.

Held: The convictions are vacated, and the case is remanded to determine whether the denial of counsel at the preliminary hearing was harmless error."

Justice Blackmun took no part in the consideration or decision of the case.

Category:United States Supreme Court cases Category:1970 in United States case law


 * This open draft remains in progress as of July 5, 2023.