Cyrus Deville Wilson v. State of Tennessee
2012 Tenn. LEXIS 288
| Tenn. | 2012Background
- Wilson was convicted of first degree murder in 1994 and sentenced to life; conviction was affirmed on appeal.
- In 2009, Wilson sought coram nobis relief asserting a December 1992 handwritten prosecutor note stating witnesses(') credibility was newly discovered exculpatory evidence.
- The note alleged the two juvenile eyewitnesses had lied repeatedly; Wilson claimed nondisclosure affected the verdict.
- The trial court tolled the one-year coram nobis statute for due process purposes but dismissed the petition.
- The Court of Criminal Appeals reversed, holding waiver of statute of limitations and remanding for merits; the Tennessee Supreme Court reversed that decision, holding the note was work product and not admissible or discoverable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness and tolling | Wilson argues due process tolling valid; state defense not raised waives limitations. | State contends timely filing; failure to raise sua sponte is not waiver. | Statute tolling proper; waiver not shown; timing upheld. |
| Discoverability and admissibility of the note | Note contains exculpatory information and would be admissible if discoverable. | Note is attorney work product, non-discoverable and inadmissible. | Note is attorney work product and inadmissible; not newly discovered evidence. |
| Whether newly discovered evidence may yield different judgment | Note could have changed trial outcome if known. | Work product bars admissibility; no basis to obtain coram nobis relief. | Even if newly discovered, not admissible; cannot support coram nobis relief. |
Key Cases Cited
- Harris v. State, 301 S.W.3d 141 (Tenn. 2010) (coram nobis statute of limitations tolled for newly discovered innocence claims)
- Workman v. State, 41 S.W.3d 100 (Tenn. 2001) (timing and tolling considerations for coram nobis)
- Burford v. State, 845 S.W.2d 204 (Tenn. 1992) (due process and meaningful opportunity to present claims)
- Pylant v. State, 263 S.W.3d 854 (Tenn. 2008) (newly discovered evidence must be admissible)
- Freshwater v. State, 160 S.W.3d 548 (Tenn. Crim. App. 2004) (test for coram nobis relief and admissibility considerations)