Christopher A. Williams v. State of Tennessee
W2017-00137-CCA-R3-ECN
| Tenn. Crim. App. | Aug 7, 2017Background
- In 1995, then-14-year-old Christopher A. Williams shot and killed Jerry McNeal; Williams gave a statement admitting the shooting and was eventually convicted of felony first-degree murder and sentenced to life. After three trials and multiple appeals/post-conviction/habeas attempts, convictions were affirmed in the late 1990s–2004.
- In 2015 Williams filed a petition for a writ of error coram nobis alleging the State withheld an anonymous informant’s interview that inculpated him and that this constituted newly discovered evidence and Brady material.
- Williams conceded the coram nobis petition was filed well beyond the one-year statute of limitations but asked the court to toll the limitations period on due-process grounds, arguing the withheld interview was material and would have caused him to accept a 20-year plea offer.
- The coram nobis court summarily dismissed the petition as time-barred and, alternatively, found the informant’s statement was cumulative, not favorable to Williams, not Brady material, and would not have changed the trial outcome.
- The Court of Criminal Appeals affirmed: the petition was untimely, the anonymous tip did not show actual innocence or constitute newly discovered favorable evidence, and tolling was inappropriate.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Timeliness of coram nobis petition | Petition should be tolled; interview was withheld so limitations should not bar review | Petition is time-barred under one-year statute; no tolling warranted | Petition untimely; no due-process tolling because claim not later-arising and not showing actual innocence |
| Whether anonymous interview is "newly discovered" evidence | Interview is newly discovered and material; would have affected plea/trial strategy | Interview is cumulative, inculpatory, and not favorable or material to defense | Not newly discovered in a way that warrants coram nobis relief; would not change outcome |
| Brady disclosure violation (suppression of exculpatory evidence) | Failure to disclose the interview violated Brady and undermined fairness | Interview was not favorable to defendant and thus not Brady material | No Brady violation: evidence was not favorable or material to an acquittal or different result |
| Use of coram nobis to attack plea decision | Would have led Williams to accept a 20‑year plea; coram nobis should address that | Coram nobis is not a vehicle to second‑guess a decision not to plead guilty | Coram nobis cannot be used to collaterally attack a decision to decline a plea; irrelevant to relief |
Key Cases Cited
- State v. Mixon, 983 S.W.2d 661 (Tenn. 1999) (coram nobis is an extraordinary remedy and narrow in scope)
- Harris v. State, 301 S.W.3d 141 (Tenn. 2010) (statute of limitations for coram nobis and due-process tolling for actual-innocence claims)
- Burford v. State, 845 S.W.2d 204 (Tenn. 1992) (due-process considerations for tolling limitations periods)
- Sands v. State, 903 S.W.2d 299 (Tenn. 1995) (Burford three-step test for later-arising claims)
- Frazier v. State, 495 S.W.3d 246 (Tenn. 2016) (coram nobis cannot be used to collateral‑attack a guilty plea decision)