Davis v. State
2016 Ark. 69
Ark.2016Background
- Adam Davis was convicted in 2008 of capital murder, attempted first-degree murder, and two firearm felonies; sentences included life without parole and 720 months; this Court affirmed on direct appeal.
- Davis filed a pro se petition asking this Court to reinvest jurisdiction in the trial court so he could seek a writ of error coram nobis.
- Coram-nobis relief is limited to fundamental factual errors extrinsic to the record (e.g., insanity at trial, coerced plea, withheld material evidence, third‑party confession) and is an extraordinary, rarely granted remedy.
- Davis principally asserted ineffective assistance of counsel, insufficiency/credibility of evidence, trial-court errors, prosecutorial misconduct, and denial of due process — all matters largely record‑based and cognizable on direct appeal or by Rule 37.1, not by coram nobis.
- The only potentially cognizable claim was incompetency at trial based on psychiatric evaluations that Davis contends were not admitted; however, he did not allege any evidence extrinsic to the record that was unknown or hidden at trial.
- The Court concluded Davis’s claims did not meet the narrow, extrinsic‑fact standard for coram nobis and denied the petition.
Issues
| Issue | Davis’s Argument | State’s Argument | Held |
|---|---|---|---|
| Whether petitioner may proceed via coram nobis for alleged ineffective assistance of counsel | Davis contends counsel was ineffective at trial and on appeal; sought to relitigate errors | Such claims are not proper in coram-nobis; they belong in Rule 37.1 or direct appeal | Denied — ineffective-assistance claims are not cognizable in coram-nobis proceedings |
| Whether insufficiency of evidence or witness credibility supports coram nobis relief | Davis argues evidence was insufficient and witnesses lacked credibility | Weight/credibility and sufficiency are record issues for trial/direct appeal, not coram-nobis | Denied — those issues are outside coram-nobis scope |
| Whether trial-court evidentiary rulings, due-process and prosecutorial-misconduct claims justify coram nobis | Davis claims various trial errors and constitutional violations prevented him from presenting desired evidence | These issues could and should have been raised at trial or on appeal; not appropriate for coram-nobis | Denied — record-based errors are not grounds for coram nobis |
| Whether mental incompetency at time of trial (psychiatric evidence) supports coram nobis | Davis asserts psychiatric evaluations were not admitted and that he was incompetent/acted in heat of passion, meriting lesser-included instruction | No allegation of extrinsic factual evidence unknown to defense at trial; claims relate to evidence that was or could have been raised then | Denied — petitioner failed to show an extrinsic, previously unknown fact necessary for coram-nobis relief |
Key Cases Cited
- Davis v. State, 348 S.W.3d 553 (Ark. 2009) (affirming convictions on direct appeal)
- Newman v. State, 354 S.W.3d 61 (Ark. 2009) (describing coram-nobis function and requirement of extrinsic fact)
- Roberts v. State, 425 S.W.3d 771 (Ark. 2013) (petitioner bears burden to demonstrate fundamental extrinsic factual error)
- Howard v. State, 403 S.W.3d 38 (Ark. 2012) (coram-nobis available only for certain narrow categories of error)
- Larimore v. State, 17 S.W.3d 87 (Ark. 2000) (coram-nobis is extraordinary and requires extrinsic evidence)
- White v. State, 460 S.W.3d 285 (Ark. 2015) (ineffective-assistance claims are not cognizable in coram-nobis)