Jackson v. State
2016 Ark. 294
| Ark. | 2016Background
- Jackson was convicted by jury of second-degree murder and sentenced to 80 years; conviction was affirmed on direct appeal.
- He repeatedly sought leave from the Arkansas Supreme Court to reinvest jurisdiction in the trial court to pursue a writ of error coram nobis — this is his fourth such petition.
- Jackson alleges the State withheld evidence of a deal/leniency given to witness Ammar Mahdi in exchange for his testimony; he submits a 2013 affidavit from Mahdi as "new" evidence.
- The record shows Jackson (and his trial counsel) had possession of Mahdi’s sentencing-transcript material during trial and declined to introduce it into evidence; the court of appeals and prior Arkansas Supreme Court orders addressed this issue in earlier petitions.
- Coram nobis relief is an extraordinary remedy limited to certain fundamental errors of fact (insanity at trial, coerced plea, prosecutorial suppression of material evidence, or third-party confession) and requires the petitioner to show the fact was extrinsic to the record and unknown despite due diligence.
- The court concluded Jackson failed to present any new, distinguishing facts from his prior petitions and therefore his successive application was an abuse of the writ; the petition was dismissed.
Issues
| Issue | Jackson's Argument | State's Argument | Held |
|---|---|---|---|
| Whether coram nobis leave should be granted based on alleged withheld impeachment evidence about Mahdi | Mahdi’s 2013 affidavit and claimed withheld sentencing-transcript evidence show the State suppressed a deal, violating due process | Jackson already knew of Mahdi’s sentencing information at trial and had access to the transcript; no new, undiscoverable fact is shown | Denied — successive coram nobis petition is abuse of writ; no distinguishing new facts |
| Whether Jackson exercised due diligence in discovering the alleged suppressed facts | Jackson contends he only recently obtained Mahdi’s affidavit and was unaware of the deal | Record and prior appeals show Jackson and counsel possessed the sentencing transcript at trial and could have pursued impeachment then | Denied — petitioner failed to show the requisite due diligence and lack of knowledge at trial |
| Whether the alleged suppression falls into a coram nobis category warranting relief | Jackson argues prosecutor withheld material evidence about witness leniency (Brady-type claim) | State argues no Brady-type suppression because evidence was available and known at trial; issue was raised before | Denied — coram nobis is improper where the fact was known or could have been presented at trial |
| Whether the court should reopen coram nobis after multiple prior petitions | Jackson seeks reconsideration based on his claimed “new” affidavit | State and court treat repeated, substantially similar petitions as misuse of the remedy; court has discretion to refuse renewals | Denied — court exercises discretion to dismiss repetitive petitions; due process does not require unlimited petitions |
Key Cases Cited
- State v. Larimore, 341 Ark. 397 (coram nobis is extraordinary; strong presumption of validity of conviction)
- Echols v. State, 360 Ark. 332 (due diligence required for coram nobis applications)
- Larimore v. State, 327 Ark. 271 (coram nobis appropriate only for facts hidden or unknown at trial)
- Brady v. Maryland, 373 U.S. 83 (suppression of material evidence violates due process)
- Westerman v. State, 456 S.W.3d 374 (presumption of validity of conviction in coram nobis proceedings)