Clark D. Frazier v. State of Tennessee
2016 Tenn. LEXIS 406
| Tenn. | 2016Background
- In 2004 Clark Derrick Frazier was charged with first-degree murder; in 2007 he pled guilty to second-degree murder and received a 25-year sentence. Post-conviction relief was denied.
- In 2011 Frazier filed a petition for writ of error coram nobis under Tenn. Code Ann. § 40-26-105(b) asserting newly discovered evidence; the trial court and Court of Criminal Appeals denied relief.
- The Tennessee Supreme Court granted review to resolve whether the coram nobis statute permits collateral attacks on convictions based on guilty pleas.
- The Court overruled its prior decision in Wlodarz v. State and held that the coram nobis statute does not apply to guilty pleas.
- The majority rested its decision on statutory construction: the statute repeatedly references "trial," "litigated," and "evidence," and does not mention pleas; the Court concluded a guilty-plea proceeding is non-adversarial, typically lacks contested evidence, and is therefore not a "trial" within the statute.
- The Court emphasized alternative remedies for defective pleas (motion to withdraw plea, post-conviction relief, Rule 11 safeguards) and affirmed the Court of Criminal Appeals' judgment on that separate ground.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a defendant who pled guilty may collaterally attack the plea via a writ of error coram nobis under Tenn. Code Ann. § 40-26-105(b) | Frazier: coram nobis is available to challenge convictions based on guilty pleas when newly discovered evidence exists and other remedies are unavailable | State: the coram nobis statute is limited to errors "dehors the record" relating to matters litigated at a trial; guilty pleas are non‑adversarial and not "trials" under the statute | The Court held coram nobis is not available to attack guilty pleas and overruled Wlodarz |
| Proper interpretation of "trial" and statutory text | Frazier: "trial" can be read broadly to include plea hearings where the court examines and determines disputed issues | State: plain meaning of "trial" denotes an adversarial proceeding with contested evidence before a factfinder; plea hearings lack that character | The Court held the statutory language is clear: "trial" refers to contested, adversarial proceedings, not plea submissions |
| Role of stare decisis in overruling Wlodarz | Frazier: prior decision stood and Congress/Legislature did not amend the statute; stare decisis favors retaining Wlodarz | State: Wlodarz was wrongly decided; correcting the error is appropriate under stare decisis exceptions | The Court overruled Wlodarz, explaining precedent may be overturned when clearly erroneous and unworkable |
| Availability of alternate remedies for defective pleas | Frazier: coram nobis is a final avenue when new evidence surfaces after plea and other remedies are unavailable | State: defendants have Rule 11 safeguards, motion to withdraw plea, and post‑conviction relief; coram nobis is not necessary for pleas | The Court noted existing remedies and procedural protections for pleas and relied on them in denying coram nobis for guilty pleas |
Key Cases Cited
- United States v. Morgan, 346 U.S. 502 (U.S. 1954) (federal coram nobis recognized as an equitable post-conviction remedy)
- Wlodarz v. State, 361 S.W.3d 490 (Tenn. 2012) (prior Tennessee decision allowing coram nobis to attack guilty pleas; overruled)
- State v. Mixon, 983 S.W.2d 661 (Tenn. 1999) (historical statutory treatment of coram nobis in Tennessee)
- Harris v. State, 301 S.W.3d 141 (Tenn. 2010) (standard that coram nobis relief is discretionary)
- State v. Vasques, 221 S.W.3d 514 (Tenn. 2007) (discussion of coram nobis standards and consideration of new evidence)
- Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (requirements for voluntariness of guilty pleas)
- Brady v. United States, 397 U.S. 742 (U.S. 1970) (guilty plea must be voluntary, knowing, and intelligent)
- North Carolina v. Alford, 400 U.S. 25 (U.S. 1970) (Alford plea doctrine permitting guilty plea while maintaining innocence)
- State v. Mackey, 553 S.W.2d 337 (Tenn. 1977) (state law safeguards in accepting guilty pleas)