Jeffery Lee Miller v. State of Tennessee
M2016-00706-CCA-R3-ECN
| Tenn. Crim. App. | May 17, 2017Background
- Jeffery Lee Miller was convicted of premeditated first-degree murder after a second trial in 1997 and sentenced to life.
- Nearly 18 years later (July 21, 2015) Miller filed a petition for writ of error coram nobis claiming newly discovered witness statements from Jeremy Gibbs and Matthew Bryant.
- Gibbs’s handwritten note allegedly contained additional details (including that he picked up a shell casing and a differing description of Miller) that could impeach testimony; Bryant’s statement said Miller fired two shots at the ground then left.
- Miller argued he only discovered these statements when he received his investigative file in August 2014 and thus was without fault for not presenting them earlier; he sought tolling of the one-year coram nobis statute of limitations on due-process grounds.
- The coram nobis court held the petition time-barred under the one-year statute, found the statements were impeachment-only and would not likely change the verdict, and denied relief; Miller appealed.
Issues
| Issue | Plaintiff's Argument (Miller) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether due process tolls the one-year coram nobis statute | Miller: He did not discover the statements until 2014, so limitations should be tolled | State: Statements existed and were available earlier; petitioner gave no reason for 17-year delay | Court: No tolling; petitioner failed to show grounds arose after limitations began and evidence showed statements likely available to trial counsel |
| Whether coram nobis court applied incorrect diligence/legal standard | Miller: Court used wrong standard regarding reasonable diligence and used rejected “would have” formulation | State: Court’s overall reasoning applied proper “may have” standard in substance | Held: No abuse; court applied correct standard in substance despite wording |
| Whether the newly discovered statements could have produced a different result | Miller: Gibbs’ note impeaches chain of custody/credibility; Bryant corroborates accident theory | State: Statements are impeachment-only and do not establish accidental shooting or negate premeditation | Held: Statements were largely impeachment-only and would not likely have changed outcome; petition fails on merits |
| Whether coram nobis court improperly relied on judicial notice of DA’s open-file policy | Miller: Court relied on personal knowledge of local practice | State: ADA and detective testified there was an open-file policy; court credited testimony | Held: No error—trial court credited state witnesses that an open-file policy existed; petitioner offered no contrary evidence |
Key Cases Cited
- Mixon v. State, 983 S.W.2d 661 (Tenn. 1999) (coram nobis is an extraordinary remedy and statute of limitations rules)
- Vasques v. State, 221 S.W.3d 514 (Tenn. 2007) (standard for evaluating effect of newly discovered evidence and impeachment material)
- Harris v. State, 301 S.W.3d 141 (Tenn. 2010) (statute-of-limitations as affirmative defense; tolling and review standards)
- Workman v. State, 41 S.W.3d 100 (Tenn. 2001) (due-process grounds may require tolling of coram nobis limitations)
- Sands v. State, 903 S.W.2d 297 (Tenn. 1995) (test for weighing tolling: when limitations begin, whether grounds arose after that, and whether strict application denies reasonable opportunity)
- Wilson v. State, 367 S.W.3d 229 (Tenn. 2012) (abuse-of-discretion review and discussion of correct coram nobis standards)
- Hall v. State, 461 S.W.3d 469 (Tenn. 2015) (standard of review for coram nobis discretionary denials)