Hill v. State
2013 Ark. 383
Ark.2013Background
- Hill was convicted in Ouachita County Circuit Court in 1995 of first-degree murder and sentenced as a habitual offender to 720 months’ imprisonment.
- In 2012 Hill filed pro se pleadings in the trial court titled Habeas Corpus; Error Coram Nobis, ACA § 16-89-130(2)(c)(4)(5)(6)(7)(d).
- The trial court denied the pleading and Hill sought review in this court.
- Hill moved to extend the page limit on his reply brief but did not show good cause beyond needing two additional pages for a notary seal and certificate of service.
- The Arkansas Supreme Court denied the motion to extend page limits, citing the obligation to conform to procedural rules even for pro se litigants and citing McDaniels v. Hobbs.
- The court ultimately affirmed the trial court’s denial of error-coram-nobis relief, finding no abuse of discretion and no sufficient basis to issue the writ.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hill established good cause to extend the page limit. | Hill (Hill) sought extra pages for notary seal and service certificate. | State contends no good cause shown; burden on conforming to rules remains. | No good cause; motion denied. |
| Whether the writ of error coram nobis should be granted for alleged withheld evidence (Brady claim). | Hill asserts withheld evidence invalidated trial; grounds for writ. | State argues no proven suppression or prejudice; insufficient for writ. | No abuse of discretion; writ denied. |
Key Cases Cited
- McDaniels v. Hobbs, 2013 Ark. 107 (Ark. 2013) (pro se litigants must meet procedural rules or show good cause)
- Lee v. State, 2012 Ark. 401 (Ark. 2012) (abuse-of-discretion standard for error-coram-nobis relief)
- Benton v. State, 2011 Ark. 211 (Ark. 2011) (abuse of discretion in denying writs)
- Pierce v. State, 2009 Ark. 606 (Ark. 2009) (per curiam on coram-nobis standards)
- Roberts v. State, 2013 Ark. 56 (Ark. 2013) (writ for fundamental-errors; rarity of granting writ)
- Camp v. State, 2012 Ark. 226 (Ark. 2012) (Brady violation requires demonstration of suppression and prejudice)
- Sparks v. State, 2012 Ark. 464 (Ark. 2012) (Brady evidence must be favorable and material to warrant writ)