McArthur v. State
2014 Ark. 367
| Ark. | 2014Background
- McArthur was convicted by a jury of capital murder in 1990 and sentenced to life without parole; this Court affirmed in 1992.
- McArthur petitions in this Court to reinvest jurisdiction in the trial court to pursue a writ of error coram nobis.
- Writs of coram nobis are rare and available only under compelling circumstances to correct fundamental errors extrinsic to the record.
- Petitioner asserts two new pieces of evidence and Brady-related claims; Hawley’s statements and a pretrial transcript are central.
- The court analyzes whether the new evidence and asserted Brady violations satisfy coram-nobis standards and whether claims are cognizable in coram-nobis proceedings.
- The petition and motion to appoint counsel are denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether new evidence warrants coram nobis relief | McArthur seeking relief based on Hawley recantations | State contends recantations do not fit coram nobis; not grounds alone | No; recantations alone are not cognizable in coram nobis |
| Whether Brady violation established | Hawley’s statement withheld; could have changed outcome | No proof prosecution knew; not enough to meet Strickler standard | No Brady violation established |
| Whether withholding evidence caused ineffective assistance | Ineffective assistance due to withheld evidence | Ineffectiveness claims are outside coram-nobis scope | Denied; issues proper under postconviction Rule 37.1, not coram nobis |
| Whether the conviction rests on false testimony | State had false testimony by Hawley | No fundamental flaw shown; sufficiency/credibility issues not for coram nobis | Not cognizable; merits addressed on direct appeal or postconviction |
| Whether counsel should be appointed | Request for appointment of counsel | Denied |
Key Cases Cited
- Hooper v. State, 2014 Ark. 16 (Ark. 2014) (permits coram-nobis petition in trial court with leave of this court)
- Cromeans v. State, 2013 Ark. 273 (Ark. 2013) (coram-nobis used sparingly for extraordinary relief)
- McDaniels v. State, 2012 Ark. 465 (Ark. 2012) (coram-nobis relief limited to fundamental errors)
- Charland v. State, 2013 Ark. 452 (Ark. 2013) (categories for coram-nobis relief include specific fundamental errors)
- Pitts v. State, 336 Ark. 580 (Ark. 1999) (requirements for Brady-based coram-nobis claims)
- Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (revised Brady framework; three elements of violation)
- United States v. Bagley, 473 U.S. 667 (U.S. 1985) (establishes standard for materiality in Brady claims)
- Anderson v. State, 2012 Ark. 270 (Ark. 2012) (recantation alone not cognizable in coram nobis)