Davis v. State
498 S.W.3d 279
Ark.2016Background
- Adam Davis, Jr. was convicted by a jury of capital murder (his wife) and attempted first-degree murder (his wife’s friend) and sentenced to life without parole plus 720 months for the attempted murder with firearm enhancements.
- Davis’s convictions and sentences were affirmed on direct appeal. He filed pro se petitions for writ of error coram nobis challenging his conviction.
- In his second coram-nobis petition Davis alleged (1) evidence showed his wife initially survived the head wound and died because police failed to render timely medical care, and (2) the prosecutor suppressed a dash-cam video, an investigator’s report, and the death certificate in violation of Brady v. Maryland.
- Davis also renewed a claim that his mental deficits rendered him incompetent to stand trial, relying on a defense-hired expert report (Dr. Speck-Kern) whose opinions were known at trial.
- The court treated coram-nobis as an extraordinary remedy, noted the abuse-of-writ doctrine for successive petitions raising the same grounds, and required new, material facts extrinsic to the record to permit a second petition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether suppressed evidence (dash-cam, investigator report, death certificate) established a Brady violation warranting coram-nobis relief | Davis: the State withheld video and reports showing police failed to check wife’s vital signs and that she initially survived, which would be favorable/impeaching | State: the challenged investigative report was consistent with the medical examiner’s trial testimony; no withheld material evidence that would have changed the outcome | Denied: Davis failed to show suppression of material evidence or a reasonable probability of a different result; allegation insufficient for coram-nobis relief |
| Whether Davis was incompetent to stand trial due to mental deficits | Davis: his mental/cognitive impairments (per Dr. Speck-Kern) meant he could not understand proceedings or assist counsel | State: Dr. Speck-Kern’s report was known at trial; Davis was found competent at trial and petitioner bears burden to show unknown facts that would establish incompetence | Denied: petitioner did not present facts unknown at trial that would overcome presumption of validity of the competency finding |
| Whether a successive coram-nobis petition alleging the same grounds should be permitted | Davis: frames prior claims within a Brady theory and adds incompetence allegations to justify a second petition | State: successive petitions raising previously rejected claims without new, material facts are an abuse of the writ | Denied: court exercised discretion to dismiss as abusive—no new facts sufficient to distinguish prior petition |
Key Cases Cited
- Davis v. State, 2009 Ark. 478, 348 S.W.3d 553 (direct-appeal decision affirming convictions)
- Newman v. State, 2009 Ark. 56, 354 S.W.3d 61 (describing coram-nobis function)
- Howard v. State, 2012 Ark. 177, 403 S.W.3d 38 (coram-nobis as extraordinary and presumptively valid conviction)
- Smith v. State, 2015 Ark. 188, 461 S.W.3d 345 (Brady allegation alone insufficient for coram-nobis relief)
- Allen v. State, 2014 Ark. 368, 440 S.W.3d 329 (abuse-of-writ doctrine for successive coram-nobis petitions)
- Goff v. State, 2012 Ark. 68, 398 S.W.3d 896 (court need not accept coram-nobis allegations at face value)
- State v. Larimore, 341 Ark. 397, 17 S.W.3d 87 (elements and materiality standard for Brady)
- Jefferson v. State, 372 Ark. 307, 276 S.W.3d 214 (proximate-cause liability principles relevant to causation argument)
- Brady v. Maryland, 373 U.S. 83 (establishing State’s duty to disclose favorable evidence)