Stenhouse v. State
497 S.W.3d 679
Ark.2016Background
- Petitioner Tishaun Stenhouse was convicted in 2004 of capital murder and committing a felony with a firearm; sentence: life without parole plus 15 years; conviction affirmed on direct appeal.
- Stenhouse sought leave to reinvest jurisdiction in the trial court to file a writ of error coram nobis alleging a Brady violation: the prosecutor suppressed exculpatory/impeaching evidence showing the victim, Braylon Gray, was armed and that eyewitnesses received undisclosed plea deals or benefits.
- New evidence attached: a 2016 affidavit by eyewitness Tiffany Williams recanting trial testimony (now says Gray had a gun, Williams hid the gun/drugs, and the prosecutor concealed that information and provided inducements to her).
- Stenhouse also submitted documents showing Brandon Landers had prior guilty pleas and lenient sentences, arguing these indicated plea deals undisclosed to defense.
- The State record at trial included multiple eyewitnesses (some testifying Gray was unarmed) and physical/forensic evidence: multiple close-range/back shots, shots fired while victim was face-down, matching casings, and GSR consistent with close-range firing; Stenhouse admitted he did not see a gun and could have retreated.
- Court framed coram-nobis as a rare remedy limited to compelling, extrinsic facts (including material evidence withheld by prosecutor) and required demonstration of materiality, suppression, prejudice, and a reasonable probability the verdict would have been different.
Issues
| Issue | Plaintiff's Argument (Stenhouse) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether petitioner alleged a Brady violation based on withheld evidence that victim was armed | Williams’s affidavit shows prosecutor suppressed that Gray had a gun and drugs; that would have supported self-defense | Trial evidence/forensics and petitioner’s own admissions show Williams’s new account would not have made self-defense reasonable | Denied — evidence (recantation) would not have prevented conviction; no reasonable probability of different outcome |
| Whether recanted testimony supports coram-nobis relief | Williams recanted trial testimony and added concealed facts; this is newly discovered, material evidence | Recantation is not cognizable for coram-nobis; cannot contradict adjudicated facts | Denied — coram-nobis cannot be used to rely on recantation to overturn verdict |
| Whether undisclosed plea deals/impeachment material for eyewitnesses were suppressed | Landers and Williams received favorable treatment/benefits; suppression undermined credibility and would have led to different verdict or lesser offense | Defense had opportunity to discover witness criminal histories and declined; record shows defense could have investigated or recalled witnesses; nondisclosure not shown | Denied — petitioner failed to show he was unaware/diligent or that impeachment would have changed result |
| Whether withheld evidence could have reduced conviction to a lesser-included offense or mitigated capital murder sentence | Disclosure would have created reasonable probability of conviction for lesser offense or mitigation | Physical evidence (multiple close-range shots to back), manner of shooting, and conduct support premeditation/deliberation; capital murder sentencing limited to death or life without parole | Denied — evidence would not have created reasonable probability of lesser conviction or mitigation |
Key Cases Cited
- Stenhouse v. State, 362 Ark. 480, 209 S.W.3d 352 (Ark. 2005) (direct-appeal decision affirming convictions)
- Roberts v. State, 425 S.W.3d 771 (Ark. 2013) (procedural requirement to obtain leave to file coram-nobis after appeal)
- Howard v. State, 403 S.W.3d 38 (Ark. 2012) (coram-nobis is rare; four categories of grounds including suppressed material evidence)
- Goff v. State, 398 S.W.3d 896 (Ark. 2012) (court need not accept coram-nobis allegations at face value)
- Smith v. State, 461 S.W.3d 345 (Ark. 2015) (Brady elements and requirement of reasonable probability the verdict would differ)
- State v. Larimore, 17 S.W.3d 87 (Ark. 2000) (sets out three Brady elements)
- Thornton v. State, 433 S.W.3d 216 (Ark. 2014) (premeditation/deliberation may be inferred from weapon use, wounds, and conduct)
- Robinson v. State, 214 S.W.3d 840 (Ark. 2005) (factors supporting premeditation)
- Coggin v. State, 156 S.W.3d 712 (Ark. 2004) (multiple close-range shots support premeditation)
- Halfacre v. State, 639 S.W.2d 734 (Ark. 1982) (self-defense depends on defendant’s awareness, not others’ conduct)
- Farris v. State, 826 S.W.2d 241 (Ark. 1992) (shooting victim multiple times from behind supports premeditation)
- Echols v. State, 125 S.W.3d 153 (Ark. 2003) (coram-nobis requires petitioner be unaware of the fact at trial and exercise due diligence)
- Thomas v. State, 241 S.W.3d 247 (Ark. 2006) (impeachment evidence must be shown to have created reasonable probability of a different result)