Petition for Writ of Certiorari — Billie Wayne Coble, Petitioner v. Texas

No.______________

In the

Supreme Court of the United States

______________________________________

EX PARTE BILLIE WAYNE COBLE,

Applicant.

______________________________________

On Petition for Writ of Certiorari to the

Texas Court of Criminal Appeals

______________________________________

PETITION FOR WRIT OF CERTIORARI

_______________________________________

CAPITAL CASE

MR. COBLE IS SCHEDULED TO BE EXECUTED ON FEBRUARY 28, 2019

A. Richard Ellis

75 Magee Avenue

Mill Valley, CA 94941

TEL: (415) 389-6771

FAX: (415) 389-0251

a.r.ellis@att.net

Counsel of Record for Applicant

Member, Supreme Court Bar

CAPITAL CASE

QUESTIONS PRESENTED

In the wake of this Court’s decision in McCoy v. Louisiana, 138 S. Ct. 1500 (2018),

two questions have emerged in the courts called on to apply that case.

The first is the manner in which a defendant must have objected to trial counsel’s

decision to forego a defense. Some courts have held that an objection to counsel alone is

sufficient. Others have held that an objection must be made to both counsel and the trial

court. In Mr. Coble’s case, the objection was lodged only with counsel.

The second question is whether McCoy applies only in circumstances where the

defendant seeks to assert his actual innocence or, more broadly, whenever the defendant

seeks to have some defense asserted rather than have his guilt conceded. In Mr. Coble’s case,

he did not seek to assert innocence but did insist that a defense be presented and that guilt

not be conceded. The conflicting answers courts have given in post-McCoy decisions call

for this Court to provide more guidance, and give rise to the following questions presented:

1. Whether the Texas Court of Criminal Appeals improperly narrowed McCoy in

light of unrefuted evidence that Petitioner expressed opposition to his lawyers

concerning their decision to drop any defense and concede guilt?

2. Whether the Texas Court of Criminal Appeals improperly narrowed McCoy to

circumstances in which the defendant’s objective was to assert actual innocence

rather than to assert some kind of defense?

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LIST OF PARTIES TO THE PROCEEDINGS BELOW

This petition stems from a habeas corpus proceeding in which Billie Wayne Coble

was the Applicant before the Texas Court of Criminal Appeals in a subsequent application

for a writ of habeas corpus. Pursuant to Sup. Ct. R. 14.1(b), the following list identifies all

the parties in previous matters.

Mr. Coble was the petitioner before the United States District Court for the Western

District of Texas, as well as the Applicant and Appellant before the United States Court of

Appeals for the Fifth Circuit and this Court. Mr. Coble is a prisoner sentenced to death and

in the custody of Lorie Davis, the Director of the Texas Department of Criminal Justice,

Institutional Division (“the Director”). The district attorney of McLennan County, Texas and

the Director and her predecessors, Rick Thaler, William Stephens, and Doug Dretke were the

Respondents before the Texas Court of Criminal Appeals, the United States District Court

for the Western District of Texas, as well as the Respondent and Appellee before the United

States Court of Appeals for the Fifth Circuit and this Court.

Mr. Coble asks that the Court issue a Writ of Certiorari to the Texas Court of Criminal

Appeals.

RULE 29.6 STATEMENT

Applicant is not a corporate entity.

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TABLE OF CONTENTS

QUESTIONS PRESENTED. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii

LIST OF PARTIES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

RULE 29.6 STATEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv

TABLE OF AUTHORITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

PETITION FOR WRIT OF CERTIORARI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

OPINION BELOW. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

STATEMENT OF JURISDICTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

CONSTITUTIONAL PROVISIONS INVOLVED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

STATEMENT OF THE CASE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

REASONS FOR GRANTING THE PETITION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

I. This Court should make clear that McCoy protects a defendant’s Sixth Amendment

right to insist upon a defense when he expressly asserts that desire to his lawyers . . . . 4

A. Courts have reached contrary conclusions about when and to whom the defendant

must object to raise a possible McCoy violation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

B. Petitioner’s unrefuted evidence that he objected to counsel’s proposal suffices to

support a McCoy claim . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

II. This Court should also make clear that McCoy also protects a defendant’s Sixth

Amendment right even if he insists upon a defense that is not a declaration of outright

innocence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

CONCLUSION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

CERTIFICATE OF SERVICE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . seperate sheet

APPENDICES TO PETITION

Appendix A: Ex parte Billie Wayne Coble, 2019 WL 640202 (Tex. Crim. App. Feb. 14,

2019)

Appendix B: Affidavit of Billie Wayne Coble, Oct. 31, 1997.

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TABLE OF AUTHORITIES

Federal Cases

Florida v. Nixon, 543 U.S. 175 (2004) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

McCoy v. Louisiana, 138 S. Ct. 1500 (2018) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . passim

Powell v. Alabama, 287 U.S. 45 (1932) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

United States v. Rosemond, 322 F.Supp. 3d 482 (S.D.N.Y. 2018). . . . . . . . . . . . . . . . . . 10

State Cases

Epperson v. Commonwealth, 2018 WL 3920226 (Ky. Aug. 16, 2018) . . . . . . . . . . . . . 7, 9

Ex Parte Coble, 2019 WL 640202 (Tex. Crim. App. Feb. 14, 2019). . . . . . . . . . . . . . . . . 1

People v. Taylor, 2018 WL 4063587 (Cal. Ct. App. Aug. 27, 2018) . . . . . . . . . . . . . . . . . 7

State v. Horn, 251 So. 3d 1069 (La. 2018) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10-11

Thompson v. Cain, 295 Or. App. 433 (2018) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Turner v. State, 2018 WL 5932241 (Tex. Crim. App. Nov. 14, 2018). . . . . . . . . . . . . . . . 8

Federal Statutes & Constitutional Provisions

28 U.S.C. § 1257 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

U.S. Const. Amend. VI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2, 10

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No.________

In the

Supreme Court of the United States

__________________________________________________

EX PARTE BILLIE WAYNE COBLE,

Applicant.

__________________________________________________

On Petition for Writ of Certiorari to the

Texas Court of Criminal Appeals

___________________________________________________

PETITION FOR WRIT OF CERTIORARI

___________________________________________________

Billie Wayne Coble respectfully petitions for a writ of certiorari to review the

judgment and decision of the Texas Court of Criminal Appeals.

OPINION BELOW

The Texas Court of Criminal Appeals decision sought to be reviewed is reported as

Ex Parte Coble, 2019 WL 640202 (Tex. Crim. App. Feb. 14, 2019), and is attached as

Appendix A.

STATEMENT OF JURISDICTION

This Court has jurisdiction over the petition pursuant to 28 U.S.C. § 1257. The

opinion of the Texas Court of Criminal Appeals is the final judgment rendered by the state

courts of Texas regarding Petitioner’s effort to seek review of his judgment under this

Court’s ruling in McCoy v. Louisiana. The Texas Court of Criminal Appeals denied

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Petitioner’s subsequent writ application on February 14, 2019. This petition follows timely

pursuant to Supreme Court Rule 13.1.

CONSTITUTIONAL PROVISIONS INVOLVED

The questions presented implicate the following provisions of the United States

Constitution:

AMEND. VI: In all criminal prosecutions, the accused shall enjoy the right . . . to have the

Assistance of Counsel for his defense.

STATEMENT OF THE CASE

Mr. Coble was convicted in 1990 for killing his wife’s parents and brother. Several

months before trial, his lawyers filed a notice of intent to raise an insanity defense. I Tr. 94.1

In jury selection, defense counsel questioned prospective jurors about how they may respond

to evidence tied to that defense. See, e.g., II VD 125-29; V VD 382-87; VI VD 486-88. Then,

after the State rested in the guilt phase, defense counsel abruptly changed course. They called

no expert witnesses or lay witnesses. Instead, the entire guilt-phase presentation consisted

of a defense investigator playing silent archival footage that depicted scenes from the

Vietnam War—a war in which Mr. Coble fought extensively as a member of the Marine

Corps some decades earlier. V SOF 712-22. In closing arguments—they did not make an

1

The citations to the state court record take the following format: Vol. # [Tr. / SOF / VD] page #.

“Tr.” refers to the Transcript, “SOF” refers to the Statement of Facts, and “VD” refers to Voir Dire.

“SH” refers to the State Habeas record.

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opening statement—they conceded Mr. Coble’s guilt. See VI SOF 757, 758. Nobody

expected defense counsel to proceed in this feeble manner. The move stunned the

prosecutors, the media, and the defendant himself. See id. at 725; Tommy Witherspoon,

Coble Attorneys Change Strategy: Lawyers for murder defendant abandon basis for insanity

plea, WACO TRIBUNE-HERALD, April 7, 1990, p. 1B. Mr. Coble did not agree with his

lawyers’ decision to drop altogether any semblance of a defense at the guilt phase and

concede his guilt. II SH Tr. 593 (Exh. 29) (attached as Appendix B).

The day before the lawyers rested their case, the lead attorney requested that the jail

medicate Mr. Coble for anxiety. II SH Tr. 583 (page from Exh. 26); IV SH SOF 209

(doctor’s testimony); V SH Tr. 1221 (trial court’s finding that defense counsel put their client

on the medication). The defendant came to court the next day under the influence of Vistaril.

Defense counsel met with Mr. Coble, informed him of their plans, and learned that he

disagreed with their charted course. VI SOF 723; II SH Tr. 593 (Appendix B). They then

prompted the court to question him about whether they had disclosed their plan. VI SOF 723.

On the back of this exchange between the client and the court, counsel called no additional

witnesses and rested their case. See id. at 725. The jury returned a guilty verdict on the

capital charge.

Federal courts completed habeas review late last year, with this Court denying a

petition for certiorari on October 9, 2018. Coble v. Davis, 139 S. Ct. 338 (2018). Petitioner

then filed a subsequent state habeas application on the ground that McCoy provided a legal

basis for guilt-phase relief that had been unavailable during the initial state habeas

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proceedings. The Texas Court of Criminal Appeals dismissed that application on February

14, 2019. In reviewing the McCoy claim, the court—instead of recognizing the constitutional

harm—employed a narrow interpretation of this Court’s holding and found that Mr. Coble

had not made “a prima facie showing” that McCoy applies. That court’s inflexible view

raises the critical questions presented that this Court should now resolve.

REASONS FOR GRANTING THE PETITION

I.

This Court should make clear that McCoy protects a defendant’s Sixth

Amendment right to insist upon a defense when he expressly asserts that desire

to his lawyers.

While defense counsel has the role and duty of making “strategic choices about how

to best achieve a client’s objectives,” the client has the autonomy to decide what those

“objectives in fact are.” McCoy v. Louisiana, 138 S. Ct. 1500, 1508 (2018) (emphasis in

original). Here, Mr. Coble’s objective was to present a defense in the guilt phase and to not

concede guilt for the crimes. Defense counsel overrode that objective—and their client’s

will—by instead presenting to the jury no defense at all and conceding his guilt. In McCoy,

this Court held that “it is the defendant’s prerogative, not counsel’s, to decide on the

objective of his defense.” Id. at 1505. The Constitution protects Mr. Coble’s right to insist

on a defense and object to the lawyers’ “proposal to concede [defendant] committed these

murders.” Id. at 1509. “[I]t was not open to [defense counsel] to override [his] objection.”

Id.

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A. Courts have reached contrary conclusions about when and to whom the

defendant must object to raise a possible McCoy violation.

This Court’s Sixth Amendment case law indicates that to have a constitutional claim

under McCoy, among other things a defendant: (1) must assert his objective before or during

trial; and (2) must direct that assertion to his counsel, the court, or both.

The first requirement emerged from Nixon, where this Court found that the question

of client “autonomy” was not at stake because the defendant “complained about the

admission of his guilt only after trial.” McCoy, 138 S. Ct. at 1509 (citing Florida v. Nixon,

543 U.S. 175, 185 (2004)).

The second requirement emerged from McCoy itself. There, this Court distinguished

Nixon because Robert McCoy, unlike Joe Nixon, repeatedly expressed his trial objective

“before and during trial.” Id. Beyond that, McCoy’s vocal assertions of innocence were

contrasted with Nixon’s “characteristic silence each time information was conveyed to him.”

Nixon, 543 U.S. at 189. McCoy made known his interests “both in conference with his

lawyer and in open court.” McCoy, 138 S. Ct. at 1509 (emphasis added). This observation,

however, did not mean that a Sixth Amendment autonomy violation can only occur when the

defendant objected both to defense counsel and to the court. Fairly read, McCoy simply

confirms that the defendant must make his objection to defense counsel or the court. In

McCoy, the defendant did both. In Nixon, the defendant did neither.

The fair reading of McCoy comes from a clear-eyed review of the majority opinion.

This Court acknowledged that a defendant’s objection to his lawyers’ proposed course of

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action may only occur off-the-record and outside the judge’s presence, during private

consultations with the client. It observed: “If, after consultations with [defense counsel]

concerning the management of the defense, [the client] disagreed with [defense counsel’s]

proposal to concede [the client’s guilt] . . . it was not open to [counsel] to override [the

client’s] objection.” Id. The Court clarified that a client’s assertion to counsel alone is enough

to give rise to the constitutional question: “Presented with express statements of the client’s

will to maintain innocence, however, counsel may not steer the ship the other way.” Id.

Placing a burden on the defendant to object to both counsel and to the court would

make little sense given the “guiding hand” counsel is meant to provide in a role that positions

her as a protector standing between the State and her client. Powell v. Alabama, 287 U.S. 45,

69 (1932). In cases where defense counsel is reluctant to reveal an attorney-client

disagreement to the court, this burden would enable only the most bold and outspoken

defendants, who summoned the courage to speak directly to the judge, to raise a potential

McCoy violation. In some cases, like Mr. Coble’s, defense counsel may not communicate or

express the client’s objection to the court, thereby defeating what would otherwise be a

constitutional violation.

Unfortunately, some courts have confused the holding of McCoy and erected

unsanctioned barriers to Sixth Amendment relief. The Kentucky Supreme Court recently

denied a defendant’s McCoy claim in part because the client’s assertion that he desired an

innocence defense did not mirror the objections present in McCoy. In its words, “Epperson

has not evidenced ‘intransigent’ or ‘vociferous’ objection to trial counsel’s strategy, nor has

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he evidenced objection to trial counsel’s strategy ‘at every opportunity, before and during

trial, both in conference with his lawyer and in open court.’” Epperson v. Commonwealth,

No. 2017-SC-000044-MR, 2018 WL 3920226, at *12 (Ky. Aug. 16, 2018), cert. denied sub

nom. Epperson v. Kentucky, No. 18-6701, 2019 WL 177659 (U.S. Jan. 14, 2019) (internal

citation omitted). This constrained reading of McCoy effectively requires the defendant to

object on the record before trial to make out an autonomy-based claim. It thus conflates

issue-preservation with the existence of an underlying constitutional claim.

Other courts see McCoy more clearly. Instead of demanding that the defendant assert

his objective in open court, the Oregon Court of Appeals recently held that the claim is

preserved if the client makes his objective known only to his lawyer: “As we read McCoy .

. . the proper inquiry is on the fundamental objective of the defendant, as expressed to

defense counsel.” Thompson v. Cain, 295 Or. App. 433, 441 (2018).

A California appellate court reached a similar conclusion. Whereas Epperson

effectively renders McCoy claims uncognizable in habeas proceedings,2 the California court

held on direct appeal that autonomy-based claims involving a non-record McCoy objection

can still be reviewed and remedied in the habeas context. See People v. Taylor, No. C084200,

2018 WL 4063587, at *5 (Cal. App. 3d Dist. Aug. 27, 2018), review denied (Nov. 28, 2018);

see also id. (observing that it is vital to know “what counsel discussed with defendant” and

2

Epperson requires an objection to be made on the record. And, unlike other constitutional

violations that are not identified by counsel during trial, McCoy violations are not susceptible to

post-conviction review through an allegation of ineffective assistance of counsel. The Court in

McCoy explicitly held that the autonomy-based violations are distinct from ineffectiveness claims.

See McCoy, 138 S. Ct. at 1511.

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whether “defendant objected to the tactical concession”).

Some courts have issued opinions that muddle McCoy’s requirements. Consider a

recent ruling from the Texas Court of Criminal Appeals. In Turner v. State, that court

responded to the prosecution’s twin arguments that the defendant did not preserve his McCoy

claim and that the record was insufficient to support the claim. It held, “[w]e agree that a

defendant cannot simply remain silent before and during trial and raise a McCoy complaint

for the first time after trial.” 2018 WL 5932241, at *20 (Tex. Crim. App. Nov. 14, 2018).

However, it did not clarify whether a defendant who lodges his complaint before or during

trial only with his counsel—and not the court—has done enough to raise a McCoy issue. (In

other words, whether objecting only to counsel is the equivalent of “remain[ing] silent” from

the court’s perspective.) Because Mr. Turner, like Mr. McCoy, had expressed his will to both

counsel and the trial court, the Texas Court of Criminal Appeals found that he had done

enough to “timely . . . ma[k]e express statements of his will . . . .” Id.

This Court should grant certiorari because courts have reached inconsistent

conclusions about when and to whom the defendant must object to raise a possible McCoy

violation. The lingering uncertainty about a core Sixth Amendment right provides a

“compelling reason” to warrant this Court’s use of its power to provide discretionary review

under Rule 10.

B. Petitioner’s unrefuted evidence that he objected to counsel’s proposal suffices

to support a McCoy claim.

Unlike Robert McCoy, Mr. Coble asserted his objective—to present a defense and not

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concede guilt—only to his lawyers before and during the trial. He did not raise his concerns

to the trial court.3 Mr. Coble presented unrefuted evidence4 in his subsequent application for

state habeas relief that he expressed his will and disagreed with his lawyers’ plan to drop his

defense. Therefore, the CCA’s holding that he “has failed to make a prima facie showing that

the recent case of...McCoy...applies to his situation” (App. A) likely turned on a reading of

McCoy that approximates the Kentucky Supreme Court’s rationale in Epperson. This case

thus presents the Court with a timely opportunity to clarify that McCoy claims are viable in

cases in which the defendant made his will known before or during trial only to defense

counsel and not to the trial court.

II. This Court should also make clear that McCoy also protects a defendant’s Sixth

Amendment right even if he insists upon a defense that is not a declaration of

outright innocence

In McCoy, this Court was confronted with a record in which the defendant

“vociferously insisted” upon his absolute innocence for the crimes with which he had been

charged. 138 S.Ct. at 1505. Given that case’s particular facts, courts have struggled with

deciding whether McCoy applies where the client’s stated objective is not as straightforward.

3

In a letter the District Attorney wrote in response to Mr. Coble’s subsequent application, he argued

“[t]he trial court held a colloquy with Applicant prior to the defense resting, wherein Applicant

expressed agreement with his counsel’s strategy . . . .” Letter at page 1. This argument

mischaracterizes the exchange that defense counsel prompted between their client and the court. As

Petitioner explained in his Application, he never actually expressed any agreement with counsel’s

decision. See Application at 35-37. Even if the exchange could be characterized as a waiver

colloquy, the waiver was not knowing, intelligent, or voluntary.

4

This support came from an affidavit the client executed in state habeas proceedings in 1997, over

two decades before this Court decided McCoy. In it, Mr. Coble stated “I was not satisfied in with

the decisions my attorney were making in not offering any defense,” and “[w]hen they decided to

rest . . . I did not agree with this decision, and I told my attorneys this.” II SH Tr. 593. (Appendix

B at *1).

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This case underscores the need for guidance.

In recognizing that “[s]ome decisions [] are reserved for the client,” this Court did not

limit the defendant’s decisional right to extend only to maintaining absolute innocence. Id.

at 1508. Instead, it focused on the defendant’s “[a]utonomy to decide [] the objective of the

defense.” Id. The opinion cited the American Bar Association’s Model Rule of Professional

Conduct 1.2(a), which provides that a “lawyer shall abide by a client’s decisions concerning

the objectives of the representation.” Id. at 1509. The Sixth Amendment autonomy protection

does not kick in exclusively upon a defendant’s proclamation that he was entirely uninvolved

in the charged criminal conduct.

However, for fear of engaging in complexities, some courts have reduced the Sixth

Amendment autonomy right about the objectives of the representation to the question of

whether the defendant wanted to maintain his innocence. See, e.g., United States v.

Rosemond, 322 F.Supp. 3d 482, 486 (S.D.N.Y. 2018) (“The Court does not read McCoy to

suggest that the ‘objective of the defendant’ relates to anything other than the defendant’s

decision to maintain innocence or concede guilt.”). On the other side—the correct one—the

Louisiana Supreme Court recently articulated the understanding that McCoy cannot and

should not be so limited. In State v. Horn, “the state suggest[ed] McCoy [was] not controlling

. . . because defendant did not claim outright innocence and instructed his attorneys to make

an argument for accidental killing under the negligent homicide statute.” 251 So. 3d 1069,

1075 (La. 2018). The court declined the State’s invitation to unduly narrow McCoy: “we

reject the state’s argument and decline to restrict application of the holding in McCoy solely

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to those cases where a defendant maintains his absolute innocence to any crime.” Id. It found

that “McCoy is broadly written” and that the autonomy to choose the objective of the defense

is not limited to assertions of actual innocence. See id.

In Mr. Coble’s case, he did not insist that his lawyers present an innocence case.

Petitioner does not deny that he bears responsibility for the victims’ loss of life, but he

nonetheless wanted his lawyers to present a defense on his behalf. They had planned for

months to proceed with an insanity defense, and Petitioner did not agree with their decision

to drop his defense and concede his guilt. These circumstances squarely present this Court

the opportunity to clarify that McCoy is not simply about insisting upon one’s innocence. The

Sixth Amendment right does not require a defendant to choose one option—absolute

innocence—or otherwise relinquish the constitutional protection. For this reason, the Court

should grant certiorari in accordance with Rule 10. See Rule 10(c) (identifying a basis for

certiorari where “a state court . . . has decided an important question that has not been, but

should be, settled by this Court”).

CONCLUSION

For the foregoing reasons, Mr. Coble respectfully requests that this Court grant the petition.

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Respectfully Submitted,

s/ A. Richard Ellis

A. Richard Ellis

75 Magee Avenue

Mill Valley, CA 94941

TEL: (415) 389-6771

FAX: (415) 389-0251

Counsel of Record,

Member, Supreme Court Bar

February 21, 2019.

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