Michael Angelo Coleman v. State of Tennessee

Summary

The Tennessee Supreme Court considered whether expert testimony may establish that a capital defendant’s functional intelligence quotient was 70 or below under Tenn. Code Ann. § 39-13-203, even when raw IQ test scores were higher. The court held that the statute does not restrict courts to raw test scores and permits competent expert testimony regarding functional IQ. The court also held that the defendant’s ineffective-assistance claim concerning mitigation evidence was procedurally barred.

Holdings

1. Section 39-13-203(a)(1) does not require courts to accept raw intelligence-test scores at face value. Courts may consider any relevant and admissible evidence, including competent expert testimony, concerning whether the defendant's functional intelligence quotient was seventy or below at the time of the offense.
2. Qualified expert testimony satisfying Tennessee Rules of Evidence 702 and 703 may be admitted to determine a defendant's functional intelligence quotient, including testimony accounting for measurement error, the Flynn effect, practice effects, and other reliable factors affecting test validity. The expert's opinion must be stated specifically rather than as an IQ range.
3. The lower courts erred by categorically excluding the testimony of Coleman's experts and by treating mental illness and intellectual disability as separate, mutually exclusive causes of adaptive limitations. The record did not support separating the effects of the two conditions, and the error could not be found harmless.
4. Howell v. State did not establish a new constitutional right that permitted Coleman to relitigate his ineffective-assistance claim. The claim remained barred by the Post-Conviction Procedure Act's statute of limitations, restrictions on reopening resolved petitions, waiver, and previous-determination provisions.

Questions Presented

1. Whether Tenn. Code Ann. § 39-13-203(a)(1) limits proof of a defendant's functional intelligence quotient to raw scores on standardized intelligence tests.
2. Whether qualified expert testimony may explain that raw intelligence-test scores do not accurately reflect a defendant's functional intelligence quotient at the time of the offense.
3. Whether the lower courts improperly excluded or discounted expert testimony concerning Coleman's adaptive behavior and improperly treated mental illness and intellectual disability as mutually exclusive causes of adaptive deficits.
4. Whether Coleman's ineffective-assistance claim concerning mitigation investigation and presentation was exempt from the Tennessee Post-Conviction Procedure Act's statute-of-limitations, reopening, waiver, and previous-determination bars based on Howell v. State.

Disposition

vacated