Hooper v. State
2015 Ark. 108
| Ark. | 2015Background
- Danny Lee Hooper was convicted by a jury in 2005 of multiple offenses (rape, kidnapping, robbery, residential burglary, third-degree battery) and sentenced as a habitual offender to an aggregate 1,320 months' imprisonment; the Arkansas Court of Appeals affirmed.
- Hooper filed a timely Rule 37.1 postconviction petition that was denied, and his appeal was dismissed as without merit.
- Hooper previously sought leave in this court to pursue a writ of error coram nobis; that first coram-nobis petition was denied.
- Hooper alleges he was incompetent at the time of trial due to prior head injuries (gunshot wound, ATV accident) and that newly obtained medical records would show Dr. Robin Ross’s pretrial competency evaluation was wrong.
- He claims suppression of medical records by Dr. Ross, the prosecutor, and others (a Brady theory), and faults trial counsel for failing to obtain/use the records and pursue an insanity defense.
- The Supreme Court of Arkansas reviewed the second petition to reinvest jurisdiction for coram-nobis relief and denied leave, finding no basis for the extraordinary writ.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether coram-nobis relief is warranted for alleged incompetence at trial | Hooper: newly obtained medical records show he was incompetent and an insanity defense was viable | State: Dr. Ross evaluated Hooper and found competence; records do not show a fundamental error undermining the conviction | Denied — petitioner failed to show extrinsic, fundamental factual error or a reasonable probability the verdict would differ |
| Whether suppression of medical records constitutes a Brady violation | Hooper: medical reports were withheld and were favorable/impeaching evidence | State: No factual showing the State withheld the records; Hooper knew examinations occurred and offers no proof of suppression | Denied — no showing the State suppressed favorable evidence; Brady not established |
| Whether newly discovered evidence (medical records) supports coram-nobis | Hooper: records are newly discovered and would have altered Dr. Ross’s opinion and trial outcome | State: Even if records existed, Dr. Ross still found competence; mere new information does not satisfy coram-nobis fundamental-error standard | Denied — new evidence alone is insufficient absent proof it would have precluded judgment |
| Whether ineffective-assistance claims can be raised via coram-nobis | Hooper: faults counsel for failing to obtain records/raise insanity defense | State: Ineffective-assistance claims are cognizable under Rule 37.1, not coram-nobis | Denied — ineffective-assistance claims are not cognizable in coram-nobis proceedings |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (suppression of favorable evidence violates due process)
- Strickler v. Greene, 527 U.S. 263 (materiality standard for Brady; reasonable probability the result would differ)
- United States v. Bagley, 473 U.S. 667 (impeaching evidence materiality standard)
- Pitts v. State, 336 Ark. 580 (coram-nobis available for certain fundamental errors)
- Penn v. State, 282 Ark. 571 (strong presumption of validity attaches to convictions)
- Troglin v. State, 257 Ark. 644 (presumption of validity for judgments of conviction)