Roger Keith Coleman v. Commonwealth of Virginia

Summary

The Supreme Court of Virginia affirmed Roger Keith Coleman's conviction of capital murder and his death sentence for the rape and slashing death of Wanda Fay McCoy. The court held that the trial court did not abuse its discretion in denying a change of venue, properly admitted Coleman's statements as non-custodial despite the absence of Miranda warnings, admitted scene and autopsy photographs, and correctly admitted hair and fluid samples taken pursuant to a consented warrantless body search. It also upheld the prosecution's cross-examination linking blood on Coleman's jeans to the victim, Instruction XIII under Code § 18.2-63.1, and found the wholly circumstantial evidence sufficient to exclude every reasonable hypothesis except guilt. Independent statutory review confirmed the death verdict rested on both continuing-threat and vileness findings and was neither arbitrarily imposed nor disproportionate.