Newman v. State
2013 Ark. 324
Ark.2013Background
- Rickey Dale Newman, sentenced to death after a 2002 capital-murder conviction, sought coram nobis relief in Van Buren County Circuit Court on two grounds: trial incompetence and undisclosed Brady material.
- The Arkansas Supreme Court previously reinvested jurisdiction for Newman to pursue those coram nobis claims. Newman v. State, 2009 Ark. 539, 354 S.W.3d 61.
- Newman appealed the circuit court’s denial of his coram nobis petition and raised multiple arguments including denial of his motion for judgment on the pleadings, trial-competency errors, suppression of exculpatory evidence (Brady), and exclusion of innocence evidence.
- Newman’s appellate filings (abstract and addendum) omitted essential portions of the trial record and the parties’ posthearing briefs submitted to the circuit court.
- The Arkansas Supreme Court held that consideration of Newman’s substantive claims requires an adequate abstract and addendum because the trial record is necessary to evaluate competency and prejudice under Brady.
- The court ordered Newman to file a substituted abstract and addendum within fifteen days to cure the deficiencies and rebrief the appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether circuit court erred in denying motion for judgment on the pleadings | Newman: trial record alone shows pervasive irrational behavior making him entitled to coram-nobis relief on competency without further hearing | State: merits require review of the trial record and proceedings | Court: cannot address without an adequate abstract; ordered rebriefing after corrected abstract/addendum |
| Whether Newman was mentally competent at trial | Newman: judge should have entertained doubt based on evidence of bizarre/irrational behavior | State: competency determination requires full trial record review | Court: competency claim cannot be resolved on appeal absent trial record in abstract; deficient filings compel rebriefing |
| Whether prosecution violated Brady by withholding exculpatory/impeachment evidence | Newman: undisclosed evidence prejudiced defense and meets Brady elements | State: court must evaluate whether suppressed evidence was favorable and prejudicial using trial context | Court: cannot assess Brady prejudice without abstract of trial; ordered rebriefing |
| Whether circuit court abused discretion by refusing to admit evidence of innocence | Newman: exclusion prevented consideration of actual-innocence support for coram nobis relief | State: admissibility determination depends on record details | Court: cannot evaluate exclusion without trial record; rebriefing required |
| Whether court should consider additional Brady claims beyond petition | Newman: court abused discretion by limiting consideration | State: procedural limits and need for specific, supported claims; record necessary | Court: appellate consideration of extra claims requires proper record and addendum; rebriefing ordered |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (establishes prosecution duty to disclose exculpatory/impeachment evidence)
- Newman v. State, 354 S.W.3d 61 (Ark. 2009) (Arkansas Supreme Court reinvested jurisdiction for coram-nobis review on competency and Brady issues)
- Howard v. State, 403 S.W.3d 38 (Ark. 2012) (sets Brady three-element framework and prejudice standard)
- Kennedy v. Morales, 2013 Ark. 41 (2013) (addendum must include related briefs concerning the challenged order)