Sovereign citizens and tax protestors—public defenders of have
represented them all. Some sovereign
citizens may not explicitly identify themselves as such, but they firmly
believe a bevy of unorthodox theories
about the U.S. government. It can be
difficult to judge whether these sovereign-citizen clients suffer from a mental
disease or whether they have simply spent too much time on the Internet. Airiz
Coleman was one such person.
The government accused Mr. Coleman of being a felon in
possession of a firearm after a bizarre interaction when a recovery agent tried
to repossess his car. In court, Mr.
Coleman’s behavior was also strange; he claimed that the court lacked
jurisdiction over him and that he was charged with a “commercial crime” for
which he did not need to answer.
This behavior continued as Mr. Coleman’s relationship with
two different lawyers broke down. Right
before his trial, he filed a host of documents with nontraditional punctuation,
capitalization, and numerous terms of legalese sprinkled throughout an
otherwise incomprehensible document. The
judge denied each of these pretrial motions.
After a jury found Mr. Coleman guilty, Mr. Coleman filed a
motion for a third attorney, dissatisfied with the result of the trial. He claimed his third attorney demanded a fee
for a not-guilty verdict, was unprepared for trial, and even that he rendered
ineffective assistance of counsel under Strickland
standard. The court denied that motion,
as well.
At the sentencing hearing, Mr. Coleman sounded a bit more
lucid. He described his troubled
upbringing and his love for his family.
He begged for mercy. But he told
the judge that, if released from prison, he had a “guaranteed job on anger
management in LA with Charlie Sheen”—a strange remark. Unmoved, the district judge sentenced Mr.
Coleman to three years’ incarceration.
On appeal, Mr. Coleman’s fourth attorney asserted that the
district court erred by failing to order a competency evaluation sua sponte. The Sixth Circuit therefore had to decide
whether there was reasonable cause to believe Mr. Coleman was suffering from a
mental disease or defect that rendered him mentally incompetent. The legal standard for incompetency is
frustratingly high. A person is
incompetent to stand trial if (1) he or she does not have a sufficient present
ability to consult with his lawyer with a reasonable degree of rational
understanding, or (2) lacks a rational and factual understanding of the
proceedings.
The Sixth Circuit noted that the district court had no
evidence that Mr. Coleman had been diagnosed with a mental illness in the
past. It also examined Mr. Coleman’s
strange behavior in court. But the court
reasoned that his repeated reference to civil legal matters, nonsensical use of
legal jargon, and unorthodox filings demonstrated that he actually knew exactly
what was going on: he knew that he was
in court, that courts cannot act without jurisdiction, and even that attorneys
must be constitutionally effective (he referenced Strickland, after all). No,
the Sixth Circuit said, he did not have a mental disease; he was just a
sovereign citizen—or at least sovereign-citizen-ish, which is a belief system,
not a mental defect. The court also
viewed Mr. Coleman’s presentation at his sentencing hearing as evidence that he
could keep it together and act relatively normal when he wanted or needed to do
so. Untroubled by Mr. Coleman’s bizarre
claim that he had guaranteed work with Charlie Sheen, the court speculated that
Mr. Coleman might be imitating the actor’s on- and off-screen behavior to gain
an advantage.
In addition, the court was not convinced that Mr. Coleman’s
potential mental illness prevented him from communicating effectively with
counsel. Instead, the court believed the
record demonstrated that Mr. Coleman was just a difficult client who was
refusing to communicate with counsel.
In short, the Sixth Circuit believed Mr. Coleman hammed up
and toned down his peculiar behavior to gain a tactical advantage. By the court’s estimation, Mr. Coleman was
just cunning.
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