Barnett v. State
461 S.W.3d 683
Ark.2015Background
- Rodney E. Barnett was convicted by a jury in Mississippi County of capital murder and sentenced to life without parole; this Court affirmed on direct appeal.
- Barnett filed a pro se petition to reinvest jurisdiction to seek a writ of error coram nobis, alleging the prosecutor withheld exculpatory evidence and allowed perjured testimony.
- He alleges the State concealed the identity and statement of a confidential informant (later identified as Floyd Riley) who, according to a third-party affidavit, was told that accomplice Donneitha Bradford implicated her boyfriend Frank Melton—not Barnett—in the killing.
- Barnett claimed this information would have impeached testimony from witnesses Larry Black (jailhouse confession) and Bradford (accomplice).
- The Court treated the petition as a request for permission to file coram-nobis proceedings in the circuit court and evaluated whether Barnett demonstrated a fundamental factual error extrinsic to the record (the heavy presumption being that convictions are valid).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether suppressed evidence (identity/statements of confidential informant) warrants coram-nobis under Brady | Barnett: State withheld informant identity and his statement that Bradford admitted killing the victim with Melton, which would impeach State witnesses | State: Informant was known (testified at related trial); record shows no concealment and no showing defense requested or was denied the information | Denied — Barnett failed to show suppressed favorable evidence or that it was unavailable at trial; no Brady violation shown |
| Whether there is a fundamental error of fact extrinsic to the record to permit coram-nobis | Barnett: New info (affidavit) reveals a fact that would have prevented conviction if known | State: Alleged facts were discoverable or already part of the public record; petitioner bears burden to show extrinsic factual error | Denied — petitioner did not meet burden to show extrinsic fundamental factual error |
| Whether withheld evidence would create reasonable probability of different outcome (prejudice) | Barnett: Informant’s statements would have impeached key witnesses and undermined verdict | State: No proof evidence was suppressed or that disclosure would have likely changed result | Denied — no reasonable probability of a different outcome shown |
| Whether petition should be permitted to proceed to circuit court | Barnett: Requests leave to reinvest jurisdiction to litigate coram-nobis claim | State: No merit shown to justify reopening; strong presumption of validity remains | Denied — petition not meritorious; leave to proceed refused |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (suppression of evidence favorable to accused violates due process)
- Strickler v. Greene, 527 U.S. 263 (1999) (Brady elements and requirement of reasonable probability of different result)
- Barnett v. State, 346 Ark. 11 (2001) (direct-appeal decision affirming Barnett’s conviction)
- Cromeans v. State, 2013 Ark. 273 (per curiam) (standards for granting leave to pursue coram-nobis after appeal)
- Sparks v. State, 2012 Ark. 464 (per curiam) (petitioner must show evidence was concealed and not reasonably discoverable at trial)
- Greene v. State, 2013 Ark. 251 (per curiam) (coram-nobis relief limited to fundamental errors; categories of remedial grounds)