Mccoy v. Louisiana

138 S.Ct. 1500 (2018)

Facts

Christine and Willie Young and Gregory Colston were shot and killed in the Youngs’ home in Bossier City, Louisiana. The three victims were the mother, stepfather, and son of D's estranged wife, Yolanda. Several days later, police arrested D. D was indicted on three counts of first-degree murder, and the prosecutor gave notice of intent to seek the death penalty. D pleaded not guilty. Throughout the proceedings, he insistently maintained he was out of State at the time of the killings and that corrupt police killed the victims when a drug deal went wrong. At defense counsel’s request, a court-appointed sanity commission examined d and found him competent to stand trial. In March 2010, Larry English, engaged by D’s parents, enrolled as D’s counsel. English eventually concluded that the evidence was overwhelming and that, absent a concession at the guilt stage that D was the killer, a death sentence would be impossible to avoid at the penalty phase. D was “furious” when told, two weeks before trial was scheduled to begin, that English would concede D’s commission of the triple murders. D told English “not to make that concession.” D sought to terminate English’s representation, and English asked to be relieved if D secured other counsel. The court refused. English told the jury there was “no way reasonably possible” that they could hear the prosecution’s evidence and reach “any other conclusion than D was the cause of these individuals’ death.” D protested, and the trial court reiterated that English was “representing” McCoy and told D that the court would not permit “any other outbursts.” Continuing his opening statement, English told the jury the evidence is “unambiguous,” “my client committed three murders.” D testified in his own defense, maintaining his innocence and pressing an alibi difficult to fathom. In his closing argument, English reiterated that D was the killer. The jury eventually returned three death verdicts. D unsuccessfully moved for a new trial, arguing that the trial court violated his constitutional rights by allowing English to concede McCoy “committed three murders,” over D’s objection. The Louisiana Supreme Court affirmed the trial court’s ruling that defense counsel had authority so to concede guilt, despite the D’s opposition to any admission of guilt. The Supreme Court granted certiorari.