Ventress v. State
2015 Ark. 181
| Ark. | 2015Background
- Petitioner Dennis J. Ventress was convicted in 1989 of capital felony murder and sentenced to life without parole; conviction affirmed on appeal.
- Petitioner pursued postconviction relief under Arkansas Rule of Criminal Procedure 36.4; relief denied and affirmed on appeal.
- In 2015, Ventress filed a pro se petition for leave to reinvest jurisdiction in the trial court to consider a writ of error coram nobis.
- Coram nobis petitions require this Court's permission before the circuit court may entertain the petition (Dansby v. State).
- Coram Nobis is an extraordinary remedy available only for compelling, fundamental-errors; categories include insanity, coerced guilty plea, withheld material evidence, or third-party confession between conviction and appeal.
- Ventress contends Brady material (statements by Ronnie Goolsby and a supposed sweetheart deal) was withheld to exculpate him; the State argues no proven Brady violation and no substantiation of additional material statements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Ventress is entitled to coram nobis relief for a Brady violation. | Ventress asserts exculpatory statements by Goolsby were withheld. | State contends no Brady violation is proven and claims lack of substantiation for withheld statements. | Denied; Brady not established and no substantial, material withheld evidence demonstrated. |
| Whether the claimed Goolsby statements and plea deal render Ventress's conviction unreliable. | Ventress argues Goolsby’s statements and plea arrangement could exculpate or impeach him. | State notes Goolsby pled guilty and testified inconsistently; claims insufficient to show Brady-type material. | Denied; coram nobis not a vehicle to relitigate trial/appeal issues or unresolved collateral disputes. |
| Whether coram nobis is available to review sufficiency of the evidence or credibility issues. | Ventress asserts insufficiency/credibility concerns were not properly addressed. | Such issues are not cognizable in coram nobis; they belong to trial/appeal proceedings. | Denied; coram nobis does not permit reexamination of trial/appeal sufficiency or credibility claims. |
| Whether Ventress’s claims regarding Goolsby’s accomplice status and plea bargain affect entitlement to relief. | Ventress claims improper treatment of an accomplice testimony and plea deal. | Accomplice status was resolved at trial; coram nobis not for rearguing trial issues. | Denied; not grounds for coram nobis relief. |
Key Cases Cited
- Pitts v. State, 336 Ark. 580, 986 S.W.2d 407 (1999) (Ark. 1999) ( Brady standard elements and materiality guidance cited)
- Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (established three Brady elements and materiality standard)
- Dansby v. State, 343 Ark. 635, 37 S.W.3d 599 (2001) (Ark. 2001) (permission prerequisite for coram nobis after direct appeal)
- Ch esterang v. State, 2014 Ark. 477 (Ark. 2014) (per curiam; coram nobis limited to fundamental errors)
- McFerrin v. State, 2012 Ark. 305 (Ark. 2012) (coram nobis rarity; limits relief to fundamental errors)
- Charland v. State, 2013 Ark. 452 (Ark. 2013) (categorization of coram nobis grounds)
- Slocum v. State, 2014 Ark. 491 (Ark. 2014) (requirement of full disclosure in coram nobis petitions)
- Wilson v. State, 2014 Ark. 273 (Ark. 2014) (burden on petitioner to show materiality/prejudice)
- Wright v. State, 2014 Ark. 25 (Ark. 2014) (per curiam on coram nobis grounds)
- Roberts v. State, 2013 Ark. 56, 425 S.W.3d 771 (Ark. 2013) (validity presumption of conviction; coram nobis limited)
- Philyaw v. State, 2014 Ark. 130 (Ark. 2014) (sufficiency/credibility issues not cognizable in coram nobis)
- Sims v. State, 2012 Ark. 458 (Ark. 2012) (issues resolved on appeal not revisitables in coram nobis)
- Lukach v. State, 2014 Ark. 451 (Ark. 2014) (coram nobis scope limitations)