Stephen Bernard Wlodarz v. State of Tennessee
2012 Tenn. LEXIS 137
| Tenn. | 2012Background
- Defendant pled best-interest guilty to first-degree murder and related offenses, receiving life without parole.
- He pursued post-conviction relief alleging ineffective counsel before filing a coram nobis petition seeking newly discovered ballistic evidence.
- Ballistic evidence indicated inconclusive matches; defendant argued the State concealed exculpatory results prior to pleas.
- Trial court denied coram nobis; Court of Criminal Appeals affirmed; this Court granted review to address whether guilty-plea convictions may be challenged via coram Nobis under Tenn. Code Ann. § 40-26-105(b).
- Court concluded that coram nobis relief based on newly discovered evidence is available post-plea only if evidence is truly new and could have changed the trial result; ballistic evidence here was not newly discovered.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether coram nobis can be used to challenge a guilty-plea conviction | Wlodarz argues coram nobis applies to guilty pleas for newly discovered evidence | State contends coram nobis cannot apply post-plea; trial already litigated voluntariness | No; plain statute bars relief for guilty-plea convictions based on newly discovered evidence. |
| Whether ballistic evidence was newly discovered | Evidentiary results were allegedly not known at trial | Evidence was known to defense and discussed prior to pleas | Ballistic evidence not newly discovered; not a basis for coram nobis. |
| Whether the plea proceeding constitutes a “trial” for the purposes of § 40-26-105(b) | Newsome-style interpretation treats guilty-plea proceedings as trial-like for coram nobis | Statutory text requires a trial; plea is not a trial | Guilty-plea proceeding qualifies as a trial for coram nobis under the statute. |
| Whether tolling or due process affects the one-year limitations period | Due process tolling permits coram nobis despite filing delay | Limitations and diligence requirements bar untimely petitions | Limitations tolled appropriately where due process requires; however here evidence failed to satisfy newness requirement. |
Key Cases Cited
- State v. Mixon, 983 S.W.2d 661 (Tenn. 1999) (writ of coram nobis is extraordinary and few cases succeed)
- State v. Vasques, 221 S.W.3d 514 (Tenn. 2007) (limits and guides for coram nobis relief in Tennessee)
- Newsome v. State, 995 S.W.2d 129 (Tenn.Crim.App. 1998) (held coram nobis could address voluntary/knowingly entered pleas based on new evidence (discussed as potential basis))
- Mixon, 983 S.W.2d 661 (Tenn. 1999) (clarified standards for newly discovered evidence and relief scope)
- Workman v. State, 41 S.W.3d 100 (Tenn. 2001) (tolling of limitations when due process requires opportunity to present claims)
- Mooney v. Holohan, 294 U.S. 103 (1935) (historical basis for coram nobis in criminal cases (federal precedent))