Ronald Cauthern v. State of Tennessee, W2015-01905-CCA-R3-ECN

In 1988 Ronald Cauthern was convicted of burglary, aggravated rape, and two counts of felony murder; after appeals and a resentencing proceeding he remains subject to ongoing capital resentencing proceedings following a Sixth Circuit habeas ruling.
In April 2014 certain trial VHS exhibits were digitized and defense counsel discovered an unedited videotape and, later, previously undisclosed TBI lab bench notes relating to blood evidence.
On April 17, 2015 Cauthern filed a writ of error coram nobis alleging Brady-type nondisclosure: (1) the unedited videotape showed officers searched/seized evidence before a warrant and possibly planted items; (2) lab bench notes showed cross‑contamination/ improper handling of blood samples.
The coram nobis court summarily denied the petition as untimely under the one‑year statute of limitations, reasoning the unedited tape had been part of the 1988 trial exhibits and available in the clerk’s file and that counsel (or subsequent counsel) could have discovered it earlier.
On appeal the Tennessee Court of Criminal Appeals affirmed that the unedited videotape claim is time‑barred but reversed as to the lab bench notes, remanding for a hearing to determine whether due‑process tolling applies to the bench‑notes claim.

Issue	Plaintiff's Argument (Cauthern)	Defendant's Argument (State)	Held
Whether coram nobis petition is timely or tolled where digitization in 2014 revealed an unedited trial exhibit the State had not produced in unredacted form	Petition timely or tolling applies because unedited tape contents were not known until digitization in 2014	Tape was part of the 1988 trial record and available in clerk’s file; petitioner and successive counsel were at fault for delay	Court: Claim as to unedited videotape is time‑barred (affirmed)
Whether lab bench notes (allegedly newly produced in 2014) are later‑arising such that due‑process tolling may apply	Lab notes were first disclosed recently and show possible contamination, so tolling required to permit coram nobis review	State argued statute of limitations bars the petition and did not materially address bench notes below	Court: Reversed and remanded for hearing to determine when notes were obtained, whether withheld, and whether tolling is warranted
Whether judgment remained nonfinal for statute‑of‑limitations purposes because of pending federal habeas/resentencing	Petition timely as to Mrs. Smith murder because resentencing remains pending	Finality for coram nobis runs from original trial judgment; allowing tolling until resentencing would frustrate finality	Court: Rejects argument; judgment became final in 1988 for limitations purposes

State v. Cauthern, 778 S.W.2d 39 (Tenn. 1989) (summary of facts and convictions from original appeal)
State v. Vasques, 221 S.W.3d 514 (Tenn. 2007) (coram nobis standards: "without fault" and "reasonably well satisfied" test)
State v. Mixon, 983 S.W.2d 661 (Tenn. 1999) (coram nobis is extraordinary remedy; due diligence requirement)
Harris v. State, 301 S.W.3d 141 (Tenn. 2010) (one‑year statute of limitations for coram nobis and statute‑of‑limitations computation)
Workman v. State, 41 S.W.3d 100 (Tenn. 2001) (due‑process tolling may be required in certain coram nobis contexts)
Sands v. State, 903 S.W.2d 297 (Tenn. 1995) (three‑step test for due‑process tolling analysis)
Cauthern v. Colson, 736 F.3d 465 (6th Cir. 2013) (federal habeas decision granting conditional writ as to two claims)