State v. Paul R. Santamaria
157 A.3d 409
N.H.2017Background
- Paul R. Santamaria was convicted of first-degree assault in 1998; his conviction was affirmed on direct appeal in 2000.
- Sixteen years later (2014) Santamaria filed a petition for a writ of coram nobis alleging ineffective assistance of trial counsel (three specific trial errors alleged).
- The superior court denied the petition as procedurally barred, finding Santamaria could have raised the claims earlier (direct appeal, motion for new trial, or habeas) and failed to show "sound reasons" for delay.
- The Supreme Court of New Hampshire accepted review to address the availability and scope of the common-law writ of coram nobis in New Hampshire and whether Santamaria met coram nobis requirements.
- The court held: (1) the common-law writ of coram nobis survives in New Hampshire (RSA 526:1 did not abrogate it); (2) regardless of whether coram nobis can reach legal errors, Santamaria failed to show sound reasons for delay and his claims were based on facts known at trial; thus relief was denied.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Santamaria) | Held |
|---|---|---|---|
| Does the common-law writ of coram nobis exist in NH or was it abrogated by RSA 526:1? | RSA 526:1 provides post-conviction relief, implying coram nobis is unnecessary | Coram nobis remains available as an extraordinary common-law remedy | RSA 526:1 does not clearly repeal the common-law writ; coram nobis survives under NH common law |
| Can coram nobis be used to raise legal errors (e.g., ineffective assistance of counsel)? | (State argued petitioner procedurally barred; did not press blanket prohibition) | Coram nobis should reach constitutional/legal errors like ineffective assistance | Court declined to decide definitively; assumed arguendo it could reach legal errors but resolved case on other grounds |
| Must petitioner show "sound reasons" for failing to seek earlier relief? | Yes; petitioner could have sought relief earlier (motion for new trial or habeas) | Could not have known of counsel defects until later; brief custody period prevented habeas filing | Court held petitioner failed to show sound reasons; claims were based on facts known at trial and could have been raised earlier |
| Was a hearing required before denying the petition? | Court proceeded without an evidentiary hearing based on the record | Santamaria argued a hearing was required (raised at oral argument) | Argument waived for lack of briefing; not considered on appeal |
Key Cases Cited
- State v. Santamaria, 145 N.H. 138 (N.H. 2000) (direct-appeal decision affirming conviction)
- United States v. Morgan, 346 U.S. 502 (U.S. 1954) (federal recognition of coram nobis to remedy constitutional errors)
- United States v. George, 676 F.3d 249 (1st Cir. 2012) (discussing rarity and nature of coram nobis relief)
- State v. Almodovar, 158 N.H. 548 (N.H. 2009) (prior NH opinion noting coram nobis in context)
- Trujillo v. State, 310 P.3d 594 (Nev. 2013) (survey of state approaches to coram nobis and constitutional-authority discussion)