Harold Coleman Hall v. Director of Corrections California State Attorney General

343 F.3d 976, 2003 WL 22072123
CourtCourt of Appeals for the Ninth Circuit
DecidedSeptember 8, 2003
Docket02-55758
StatusPublished
Cited by51 cases

This text of 343 F.3d 976 (Harold Coleman Hall v. Director of Corrections California State Attorney General) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harold Coleman Hall v. Director of Corrections California State Attorney General, 343 F.3d 976, 2003 WL 22072123 (9th Cir. 2003).

Opinions

PER CURIAM Opinion; Dissenting Opinion by Judge TALLMAN.

[978]*978PER CURIAM:

In 1990, California state prisoner Harold Coleman Hall was convicted by a jury of first degree murder for the killing of Nola Duncan.1 The conviction was based almost entirely on Hall’s confession, obtained while Hall was in custody for an unrelated crime. The confession, however, was rather suspect, as the subsequent police investigation revealed that various aspects of it were clearly untrue. Unable to find any physical evidence to connect Hall to the murder, the prosecution relied upon two documents provided by a jailhouse informant, Cornelius Lee, to corroborate Hall’s confession. These “jailhouse notes” •were admitted at trial without testimony by the informant as to their authenticity.

The notes purported to be a series of questions and answers between Lee and Hall; after the trial, however, Lee confessed he had submitted innocent or innocuous questions to Hall and then erased and altered them after Hall had written his answers in order to make them incriminating.2 Expert testimony confirmed that erasures had been made on the documents. After hearing testimony regarding the falsification of the jailhouse notes, the state trial judge who had originally tried the case concluded that a new trial was necessary. The California Court of Appeal reversed, finding that Hall had not proven the notes were false, apparently believing the state trial judge had not found falsity either. Today we hold that the California Court of Appeal’s decision was an unreasonable determination of the facts in light of the evidence presented to the state court. The falsification of this material evidence violated Hall’s due process rights, and a new trial is required.

I.

Hall was taken into custody on August 17, 1985, for a robbery unrelated to the Duncan murder. He was placed in an area of the jail known as “informant’s row.” On September 5, 1985, based on information received from informants, police interviewed Hall regarding his possible involvement in Duncan’s murder. Hall told Detective Crocker that while visiting a friend at 48th and Vermont, he observed the body of a dead female in the alley. Hall also stated that two days later, while talking with Jerry Knox and Terry Ross at a beauty salon, he heard Knox brag that he had killed a woman and dumped her body in an alley.

On September 9, 1985, Crocker interviewed Hall and showed him two photo lineups containing pictures of Knox and Ross. Hall correctly identified the photos of Knox and Ross. During this interview, Hall told the detective that Knox and Ross had raped and stabbed Duncan. He stated that he was in the car with Knox and Ross when they transported Duncan’s body and dumped it in the alley.

Detectives Crocker and Arneson subsequently discovered that Knox was in prison at the time of the murders. On September 11, 1985, Detectives Crocker and Arneson interviewed Hall again at the jail. For the first time, the police gave Hall Miranda warnings. They thereafter confronted him with this information, and told [979]*979him they knew he was lying. This time Hall implicated himself in the murder, stating that he arrived at the beauty shop at 47th Street and Vermont in the early morning hours on June 27, 1985. Duncan was being held there in a back room by four men, one of whom was Terry Ross. Hall and the other men took turns raping Duncan. The other men took turns stabbing Duncan. Hall stabbed Duncan twice in the arm. The men then placed Duncan’s body in the trunk of a car and three of them, including Hall, drove to the alley and dumped the body there. Hall gave a description of the position of the body that matched the police crime scene description. The men then discussed returning to kill Rainey, because he knew that his sister, Nola Duncan, was with them. Hall left the group at that point and heard later that Rainey had been killed. Detective Crocker reduced this statement to writing, and Hall signed it.

On September 20, 1985, Detective Arne-son was given two documents by Lee, an inmate on “informant’s row” in Los Ange-les County Jail. The two documents were notes which Lee indicated had been passed back and forth between himself and Hall, with Lee posing questions and Hall answering them. The contents of the notes, including spelling and grammatical errors, were as follows:

Q: “After you guys killed the gril, did you and V-Dog kill her brother two[?]”
A: “possible.”
Q: “Okay, befor you guys killed her. Did she in joy you makeing her make love to you how could you tell[?]”
A: “Cause she was saying she did.”
Q: “Hey, home boy the police want you and V-Dog bad for killing that gril on 49th and Vemout. Listing you are going to have to stop tell people that you killed that gril. Okay when you guys put her in alley, who seen her[?]”
A: “Everybody was their the whole Neabior Hood even old people.”
Q: “Did you killing that gril on 49th and Vermout. And why did you tell the ploice they know you did it[?]”
A: “(That yes) because they said They will book me if I ly.”

(E.R. at 252.)

At trial, the defense offered evidence that Hall’s two oral statements were contradictory, and his written statement contained multiple facts that contradicted evidence from the crime scene. According to Hall’s written confession, Todd Smith initiated and directed Duncan’s rape and murder, and her body was transported in Smith’s car from the beauty parlor to the alley. Smith was questioned by Detective Arneson. Smith admitted knowing Hall, but denied any knowledge of or involvement in the murders. Smith’s car was examined by police; his tires did not match the prints of those found in the alley, and a forensic examination of his car did not reveal any evidence linking it to the crime or to Hall. Smith was never arrested or charged.

According to Hall’s confession, the back room of the beauty parlor where Duncan was raped and murdered was at 47th and Vermont. At trial, the owners of the beauty salon at that location testified that it had no back room, and that there had never been signs of a forced entry, or blood, or evidence of any bizarre occurrence. The owners testified that they were not contacted by police. Detective Arneson testified that he did not search the beauty salon because he never believed it was the scene of the crime.

Hall’s confession stated that Duncan was repeatedly raped prior to her murder. At trial, the forensic pathologist testified that it was his opinion that Duncan had not engaged in sexual activity for at least two [980]*980hours prior to her death. According to Hall, when Duncan was stabbed, her blouse was open, her brassiere was off, and she was otherwise naked. The forensic pathologist contradicted this, stating that his examination indicated that Duncan’s clothing had been moved or removed after her death. Cuts in her brassiere matched stab wounds on her chest, and blood on the pants indicated she was probably wearing her pants when she was stabbed.

Hall also attempted to show that the murders were committed by someone else.

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Cite This Page — Counsel Stack

Bluebook (online)
343 F.3d 976, 2003 WL 22072123, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harold-coleman-hall-v-director-of-corrections-california-state-attorney-ca9-2003.