Schrader v. State
2014 Ark. 379
| Ark. | 2014Background
- Charles Schrader pleaded guilty in 2011 to three counts of rape and received three consecutive life sentences imposed by a jury.
- In 2013 Schrader filed a combined petition in Greene County circuit court seeking a writ of error coram nobis, declaratory relief, and alternatively habeas corpus; the court denied relief and he appealed only the coram-nobis claim.
- Schrader argued trial counsel prevented him from accepting a pretrial plea offer for a 30-year term, so his guilty plea was coerced and reflected ineffective assistance of counsel; he sought coram-nobis relief because Rule 37.1 postconviction time limits had expired.
- He relied on 2012 U.S. Supreme Court decisions (Frye and Lafler) to show prejudice and argued those decisions only became available after his Rule 37.1 deadline had passed.
- The trial court denied the petition without an evidentiary hearing as outside coram-nobis relief; the Arkansas Supreme Court considered whether coram-nobis may be used to raise ineffective-assistance-of-counsel claims about plea advice or advice that prevented acceptance of a plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether coram-nobis may be used to raise ineffective-assistance claims about counsel's plea advice or refusal to permit acceptance of a plea | Schrader: coram-nobis should issue because counsel barred acceptance of a 30-year plea — a fundamental extrinsic error warranting relief | State: ineffective-assistance claims belong in a timely Rule 37.1 petition, not coram-nobis; existing precedent forbids expansion | Court: coram-nobis cannot be used to raise ineffective-assistance-of-counsel plea claims; relief denied |
| Whether Frye/Lafler entitle Schrader to coram-nobis because Rule 37.1 time to file had lapsed before those decisions | Schrader: Frye/Lafler were decided after his Rule 37.1 deadline, so coram-nobis should be available to avoid a procedural bar | State: Schrader offered no authority that Frye/Lafler (or Padilla) apply retroactively to resurrect untimely Rule 37 claims | Court: no retroactivity argument supports coram-nobis; Chaidez controls retroactivity questions and Schrader did not show entitlement |
| Whether Tejeda‑Acosta / Estrada require expanding coram-nobis categories to include Padilla‑type claims | Schrader: Tejeda‑Acosta is distinguishable because he lost a materially better plea and received life sentences | State: Tejeda‑Acosta and Estrada foreclose expanding coram-nobis to ineffective‑assistance claims | Court: declined to expand coram-nobis categories; adhered to Tejeda‑Acosta and Estrada |
| Whether an evidentiary hearing was required on the coram-nobis petition | Schrader: requested an evidentiary hearing to prove his factual allegations about the plea offer and counsel's conduct | State: petition failed to state a cognizable coram-nobis claim, so no hearing necessary | Court: no hearing required where petition clearly falls outside coram-nobis relief; denial affirmed |
Key Cases Cited
- Padilla v. Kentucky, 559 U.S. 356 (2010) (counsel’s failure to advise about deportation can be ineffective assistance)
- Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel)
- Missouri v. Frye, 132 S. Ct. 1399 (2012) (prosecutor’s pretrial plea-offer duties and counsel’s role)
- Lafler v. Cooper, 132 S. Ct. 1376 (2012) (prejudice from counsel’s performance in plea negotiations)
- Chaidez v. United States, 133 S. Ct. 1103 (2013) (Padilla rule not retroactive to cases on collateral review)
- State v. Tejeda‑Acosta, 427 S.W.3d 673 (Ark. 2013) (refusing to expand coram-nobis to Padilla‑type ineffective‑assistance claims)
- Deaton v. State, 285 S.W.3d 611 (Ark. 2008) (no hearing required where coram-nobis petition clearly lacks merit)