ADRIAN LOUIS CARNER v. STATE OF ARKANSAS
535 S.W.3d 634
Ark.2018Background
- Adrian Louis Carner was convicted in 2003 of first-degree murder; the Arkansas Court of Appeals affirmed the conviction.
- Carner filed a pro se petition in the Arkansas Supreme Court seeking reinvestment of jurisdiction to pursue a writ of error coram nobis after his direct appeal concluded.
- He alleged: insufficient evidence of guilt, trial errors, appellate/court failures to properly review the record, and a Brady violation (prosecutorial reference to his prior criminal history that he asserts was improper/suppressed).
- The Supreme Court explained coram nobis is an extraordinary remedy available only for narrow, fundamental errors of fact extrinsic to the record and enumerated statutory categories (e.g., withheld material evidence).
- The Court evaluated each category of Carner’s claims and found they either were direct attacks on the conviction, trial/appellate errors, or conclusory Brady assertions lacking factual support.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Carner: trial evidence was insufficient to prove first-degree murder | State: sufficiency challenges are direct appeals, not coram nobis | Denied — insufficiency claims are not cognizable in coram nobis |
| Trial errors | Carner: various trial errors occurred | State: alleged trial errors were or could have been raised at trial/appeal; coram nobis not vehicle to relitigate | Denied — trial-error claims outside coram nobis scope |
| Appellate review challenged | Carner: appellate courts (Ct. App. and Supreme Ct.) failed to properly review evidence | State: review/requests for rehearing must follow appellate rules; coram nobis cannot challenge appellate review | Denied — appellate-review complaints not remediable via coram nobis |
| Brady claim (suppressed/improper reference to prior) | Carner: State referenced/suppressed evidence regarding his prior, causing prejudice | State: Carner pleads only a conclusory allegation without factual support that evidence was suppressed or material | Denied — no factual basis pleaded to establish a Brady violation |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (prosecution’s suppression of material, favorable evidence violates due process)
- Strickler v. Greene, 527 U.S. 263 (elements required to establish a Brady violation)
- Newman v. State, 2009 Ark. 539 (trial court cannot entertain coram nobis after appeal unless Supreme Court grants permission)
- Howard v. State, 2012 Ark. 177 (coram nobis available only for limited categories of fundamental errors)
- Grady v. State, 2017 Ark. 245 (sufficiency challenges are direct attacks, not coram nobis relief)
- State v. Larimore, 341 Ark. 397 (coram nobis is extraordinarily rare; strong presumption of validity of conviction)