Coleman v. Bradshaw, No. 15-3442 (6th Cir. 2020)
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In January 1996, Coleman killed Stevens to keep her from testifying against him at his trial on charges of drug trafficking. A jury convicted him for aggravated murder (with a capital-specification for his killing a witness and a firearm-specification) and of unlawful possession of a firearm. The Ohio trial court sentenced him to death and four-and-a-half years in prison.
Coleman unsuccessfully sought relief on direct appeal, then unsuccessfully pursued state post0conviction relief. While Coleman’s first petition for post-conviction relief was pending, he returned to the trial court in 2002, with a motion for relief from judgment, a motion for a new trial, and a successive petition for postconviction relief, all raising claims of actual innocence and that the prosecution withheld exculpatory evidence in violation of “Brady.” The court dismissed the petition without a hearing, The Ohio appellate court affirmed.
The Sixth Circuit affirmed the denial of his federal habeas petition. The decision of the Ohio court of appeals, that a purported confession by another inmate lacked credibility and was not “Brady” material, neither contravened nor unreasonably applied clearly established Supreme Court precedent. The state court evaluated the totality of the mitigation evidence and reweighed it against the evidence in aggravation to reasonably conclude that Coleman experienced no prejudice from his counsel’s conduct in failing to raise certain mitigation arguments.
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