State of Tennessee v. Derrick Richardson, E2016-02293-CCA-R3-ECN

Derrick Richardson was convicted in 1992 of first-degree felony murder and sentenced to life; conviction affirmed on direct appeal.
Key trial testimony: LaKeysh Davis testified she observed Richardson and others rob and shoot the victim; Richardson admitted firing at the victim’s vehicle but denied shooting the victim and claimed others fired the fatal shots.
Richardson previously pursued post-conviction relief and habeas petitions raising ineffective assistance and alleged perjured testimony; those efforts were denied or dismissed.
In 2016 Richardson filed a petition for writ of error coram nobis submitting affidavits (Tony Richardson, Tinika Bates, Fred Conyers) claiming Davis could not have seen the shooting and therefore lied at trial.
At a multi-day coram nobis hearing, witnesses gave conflicting accounts; the court found Tony Richardson and Bates’ statements were not newly discovered but deemed Conyers’ testimony newly discovered yet of questionable veracity because he was likely incarcerated at the time of the homicide.
The coram nobis court concluded the new evidence would not reasonably have produced a different verdict (notwithstanding some evidence being newly discovered) and denied relief; the Court of Criminal Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether affidavits amount to newly discovered evidence warranting coram nobis relief	Richardson: affidavits show Davis could not have seen the shooting and thus her trial testimony was false	State: most affidavit testimony was known or discoverable earlier; one witness’s account (Conyers) unreliable	Court: Tony Richardson and Bates not newly discovered; Conyers treated as newly discovered but unreliable; overall no coram nobis relief
Whether petitioner was "without fault" for failing to present the evidence earlier	Richardson: could not present earlier because witnesses recanted only recently	State: petitioner knew of brother’s presence and Bates as potential witness earlier	Held: petitioner was at fault regarding brother and Bates; due process allowed consideration of Conyers’ late evidence but it was unpersuasive
Whether newly discovered evidence would likely produce a different result at trial	Richardson: recantations/exculpatory accounts could undermine Davis and change outcome	State: Richardson’s own trial admissions (firing at vehicle, handling wallet) still incriminating	Held: No reasonable basis that new evidence would have altered verdict
Whether coram nobis court abused discretion or relied on incomplete record	Richardson: court based decision on portion of trial record	State: court had sufficient material including trial transcript of Davis and appellate opinions	Held: No abuse of discretion; judgment affirmed

State v. Mixon, 983 S.W.2d 661 (Tenn. 1999) (coram nobis is an extraordinary, narrow remedy)
Harris v. State, 102 S.W.3d 587 (Tenn. 2003) (coram nobis may be based on any newly discovered evidence if petitioner was without fault)
State v. Vasques, 221 S.W.3d 514 (Tenn. Ct. Crim. App.) (trial court must assess veracity of new evidence and whether it could have changed outcome)