Mason v. State
2014 Ark. 288
| Ark. | 2014Background
- Mason was convicted in 2007 of two counts of aggravated robbery, two counts of theft of property, and one count of second-degree battery, receiving a 660-month aggregate sentence.
- The Arkansas Court of Appeals affirmed the conviction and sentence.
- Mason filed a pro se petition in the Arkansas Supreme Court seeking reinvestment of jurisdiction in the trial court to pursue a writ of error coram nobis.
- Coram nobis is available only under compelling circumstances to address fundamental extrinsic errors, and requires jurisdictional reinvestment by this court for post‑affirmation petitions.
- Coram-nobis claims are limited to four categories: insanity at trial, coerced guilty plea, withheld material evidence, or a third-party confession; petitioner bears the burden to show a fundamental extrinsic error.
- Petitioner alleged ineffective assistance of counsel, denial of a continuance to call a defense witness, and a Brady violation regarding a victim’s statement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ineffective assistance claims are cognizable in coram nobis. | Mason asserts trial/appeal counsel errors warrant relief. | Ineffective assistance is outside coram nobis; must be raised under Rule 37.1. | No; coram nobis not available for ineffectiveness claims. |
| Whether denial of a continuance to secure a defense witness supports coram-nobis relief. | Continuance denial prevented defense witness Nicholas Mason from testifying. | Rulings on continuances are trial‑level issues; not grounds for coram nobis. | No; such rulings could be reviewed on direct appeal, not via coram nobis. |
| Whether the Brady violation claim regarding the victim’s statement supports coram-nobis relief. | The victim’s statement was withheld, violating Brady and prejudicing Mason. | No demonstrated favorable evidence, suppression, or prejudice; insufficient to show a Brady violation. | No; petitioner failed to show the statement was favorable, suppressed, or prejudicial; coram nobis denied. |
Key Cases Cited
- Charland v. State, 2013 Ark. 452 (Ark. 2013) (limits coram-nobis to narrow categories and burden on petitioner)
- Cromeans v. State, 2013 Ark. 273 (Ark. 2013) (writ available only for fundamental extrinsic errors)
- Pitts v. State, 336 Ark. 580 (Ark. 1999) (Brady material, if any, must be shown to have altered outcome)
- Strickler v. Greene, 527 U.S. 263 (U.S. Supreme Court, 1999) (three elements of Brady violation: favorable, suppressed, prejudicial)
- United States v. Bagley, 473 U.S. 667 (U.S. Supreme Court, 1985) (definition of material evidence favorable to the defense)
- Williams v. State, 2011 Ark. 541 (Ark. 2011) (coram-nobis burdens and presumptions)
- McFerrin v. State, 2012 Ark. 305 (Ark. 2012) (coram-nobis relief tied to fundamental error doctrine)