Stephen Lynn Hugueley v. State of Tennessee, W2016-01428-CCA-R3-ECN

Stephen Lynn Hugueley, already serving two life sentences, was convicted in 2003 of first-degree premeditated murder and sentenced to death for the 2002 prison killing of a counselor; he waived guilt‑phase defense and mitigating evidence at sentencing.
Hugueley has a long documented psychiatric history (juvenile institutionalization, tumor removed in 1986, diagnoses including intermittent explosive and antisocial disorders) and prior competency evaluations (Dr. Keith Caruso in 2003; Dr. Bruce Seidner in 2008) found him competent to stand trial and competent to withdraw a 2008 post‑conviction petition.
In 2013 an MRI revealed congenital brain abnormalities; two later experts (Dr. George Woods and others) opined Hugueley had been incompetent at trial and when he withdrew his post‑conviction petition, and currently incompetent.
Hugueley’s aunt filed a writ of error coram nobis in 2014 asserting the post‑2013 imaging and expert opinions were "newly discovered evidence" that would invalidate the conviction/sentence or his prior waivers.
The coram nobis court denied relief; on appeal the Tennessee Court of Criminal Appeals affirmed, holding the claim untimely, not newly discovered, and legally unsuited for coram nobis because incompetency would negate entry of any judgment (not produce a "different judgment").

Issue	Hugueley’s Argument	State’s Argument	Held
Timeliness of coram nobis petition	Filed within one year of discovery (2013 MRI); thus timely	Petition filed 2014 was well beyond one‑year statute; no tolling warranted	Petition untimely; Burford tolling denied because claim not "later‑arising" and not actual‑innocence
Whether 2013 MRI/expert opinions are "newly discovered evidence"	MRI and new expert opinions show longstanding incompetence and are newly discovered factual predicate	Mental‑health issues were known and litigated earlier; new opinions just disagreement with prior experts	Not newly discovered; repackaging of long‑known psychiatric history
Availability of coram nobis for incompetency claims	Incompetency evidence would have changed proceedings; coram nobis appropriate	Coram nobis applies to newly discovered evidence that could have produced a different judgment at trial; incompetency would have prevented any judgment (so not a "different judgment") and competency is decided pretrial	Coram nobis is improper vehicle for challenging competency to stand trial or to waive post‑conviction relief; petition fails on merits
Next‑friend standing to file coram nobis	Aunt filed on his behalf; allowed for limited purpose	State did not contest on appeal	Court permitted limited next‑friend filing for purposes of the petition

State v. Mixon, 983 S.W.2d 661 (Tenn. 1999) (coram nobis is an extraordinary, narrow remedy)
State v. Vasques, 221 S.W.3d 514 (Tenn. 2007) (standard for whether newly discovered evidence might have produced a different judgment)
Harris v. State, 301 S.W.3d 141 (Tenn. 2010) (coram nobis relief rests in trial court discretion; statute of limitations considerations)
State v. Wilson, 367 S.W.3d 229 (Tenn. 2012) (statute of limitations for coram nobis may be tolled for newly discovered evidence of actual innocence)
Workman v. State, 41 S.W.3d 100 (Tenn. 2001) (due‑process balancing when tolling limitations is sought)
Burford v. State, 845 S.W.2d 204 (Tenn. 1992) (three‑step test for whether limitations should be tolled for later‑arising claims)
Sands v. State, 903 S.W.2d 297 (Tenn. 1995) (articulation of Burford rule)
Payne v. State, 493 S.W.3d 478 (Tenn. 2016) (intellectual disability does not establish actual innocence of the underlying offense)
State v. Bailey, 213 S.W.3d 907 (Tenn. Crim. App. 2006) (procedures when a defendant is found incompetent)
Newsome v. State, 995 S.W.2d 129 (Tenn. Crim. App. 1998) (newly discovered evidence must be admissible at retrial)