In an order filed Monday, the Tennessee Supreme Court rejected a petition to appeal filed by death row inmate Michael Angelo Coleman whose victim was shot to death during a 1979 Memphis robbery.
Coleman, 42, was convicted and sentenced to death for the murder of 69-year-old Leon Watson. The victim was killed in his car after leaving home to go to a nearby grocery store. Coleman confessed to the crime and led police to Watson’s body, which had been left in a field. Watson’s empty wallet and items from his automobile were scattered near his body.
The Supreme Court upheld Coleman’s conviction and death sentence on direct appeal in 1981. His first post-conviction petition was denied by the court in 1984. A second post- conviction petition, claiming Coleman was entitled to a new sentencing hearing, was filed in 1993, dismissed by the trial court in 1996 and denied by the Court of Criminal Appeals in 1998.
At his sentencing hearing, jurors found two aggravating circumstances which outweighed mitigating circumstances, making Coleman eligible under Tennessee law to receive the death penalty. In his second appeal, Coleman claimed his death sentence should be overturned because one of the aggravating circumstances - felony murder - was deemed constitutionally invalid pursuant to a 1992 Supreme Court ruling which held invalid the use of felony murder as an aggravating circumstance to impose the death penalty where it duplicated the underlying conviction of felony murder, or murder committed during a felony crime.
The Court of Criminal Appeals, in its 1998 opinion, said the other aggravating factor - Coleman’s six previous convictions for violent felonies - outweighed mitigating factors and his sentence would have been the same without the felony murder aggravator.
Since the 1995 enactment of the state Post Conviction Procedures Act, Tennessee inmates hoping to have their sentences overturned have been limited to a single post-conviction petition in state courts in most cases. The law also requires that the petitions for post-conviction relief be filed within one year of the final judgment or final action taken by a state appellate court.