Rice v. State
479 S.W.3d 555
Ark.2016Background
- Rice was convicted in 2010 for possession of cocaine and resisting arrest, sentenced as a habitual offender to 360 months in prison.
- The Arkansas Court of Appeals affirmed the conviction; the denial of postconviction relief followed in 2012.
- Rice filed a pro se petition to reinvest jurisdiction in the trial court to pursue a writ of error coram nobis after direct appeal.
- Coram-nobis relief is granted only under compelling circumstances to address fundamental errors extrinsic to the record.
- Rice alleged Brady material was withheld—the videotape of his arrest—which he claimed would prove misrepresentation and innocence.
- The court held no Brady violation existed and ultimately denied the coram nobis petition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was a Brady violation | Rice argues evidence (the videotape) was withheld by the State. | State contends the tape was discussed at pretrial and played at trial; no withholding occurred. | No Brady violation; tape was discussed and presented. |
| Whether coram nobis relief is available for alleged issues | Rice asserts the arrest tape and credibility issues warrant relief. | Coram-nobis available only for fundamental errors; issues were attacks on credibility/sufficiency. | Coram-nobis relief not warranted for these claims. |
| Whether Rice acted with due diligence to pursue coram nobis | Rice waited four years post-affirmance to bring claims. | Diligence is required; delay lessens likelihood of relief. | Court need not address due diligence because no ground for the writ was shown. |
Key Cases Cited
- Strickler v. Greene, 527 U.S. 263 (1999) (reasonable-probability standard for undisclosed Brady material)
- United States v. Bagley, 473 U.S. 667 (1985) (material evidence; reasonable probability it would have altered outcome)
- Newman v. State, 354 S.W.3d 61 (2009) (standard for granting permission to reinvest jurisdiction in coram nobis)
- Westerman v. State, 456 S.W.3d 374 (2015) (coram-nobis requires strong presumption of valid judgment; exceptional relief)
- Roberts v. State, 425 S.W.3d 771 (2013) (burden on petitioner; extrinsic-factor standard for coram nobis)
- Riley v. State, 741 S.W.2d 246 (2015) (direct attacks on trial evidence; credibility issues not coram nobis relief)
- McArthur v. State, 439 S.W.3d 681 (2014) (sufficiency/credibility attacks not cognizable in coram-nobis)
- Nelson v. State, 431 S.W.3d 852 (2014) (due-diligence considerations in writ petitions)