Wallace v. State
2015 Ark. 349
| Ark. | 2015Background
- Wallace was convicted of first-degree murder in 2002 and sentenced as a habitual offender to 480 months in prison; the Arkansas Court of Appeals affirmed (Wallace I, 2004).
- In 2005 Wallace filed a pro se petition to reinvest jurisdiction in the trial court for a writ of error coram Nobis; this court denied in Wallace II (2005).
- Wallace filed a second pro se petition in 2015 seeking reinvestment to pursue coram-nobis relief; the court denied, and treated an amended petition as denied; hearing request was moot.
- Wallace’s arguments center on alleged Brady violations, newly discovered evidence, and third-party confessions raised via affidavits after trial and appeal.
- The core factual backdrop includes competing witness accounts regarding Petties’s murder, disputed impeachment avenues, and undeveloped statements from potential witnesses such as Demetrius Spencer and others.
- The court held that coram-nobis relief is not warranted here because the affidavits and newly asserted evidence fail to demonstrate grounds for relief, and several claims are not cognizable in coram-nobis proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether coram-nobis relief is warranted on Wallace’s post‑affirmance petitions | Wallace contends newly discovered evidence and third‑party admissions invalidate trial. | State argues petitions are untimely and lack grounds for coram-nobis relief. | Denied; no grounds shown for reinvestment or relief. |
| Whether the affidavits constitute newly discovered evidence or third‑party confessions | Affidavits show others confessed and could exonerate Wallace. | Affidavits are credibility questions; not new evidence leading to relief. | Affidavits insufficient to warrant coram-nobis relief; credibility issues preclude relief. |
| Whether Wallace can pursue due-process/Brady claims in coram-nobis proceeding | State withheld exculpatory evidence; Brady standard applies. | Claims not cognizable or insufficient under coram-nobis framework. | Key Brady claims not supported; relief denied. |
| Whether Wallace’s sufficiency of evidence and related due-process claims are cognizable | Argues insufficient evidence and unequal treatment of codefendants. | Sufficiency challenges are not within coram-nobis scope. | Not cognizable in coram-nobis; denied. |
Key Cases Cited
- Strickler v. Greene, 527 U.S. 263 (1999) ( Brady framework elements; disclosure standards.)
- United States v. Bagley, 473 U.S. 667 (1985) (material evidence favorable to the defense; prejudice required.)
- Newman v. State, 354 S.W.3d 61 (Ark. 2009) (coram-nobis availability and burden; timing considerations.)
- Wallace v. State, Erroneous tocite; cited within opinion (—) (background of Wallace I/II and coram-nobis treatment.)
- Howard v. State, 403 S.W.3d 38 (Ark. 2012) (limitations of coram-nobis for ineffective assistance claims.)
- Lee v. State, 11 S.W.3d 553 (2000) (burdens and standards for impeachment evidence.)
- Brown v. State, 955 S.W.2d 901 (1997) (third-party confession timing and admissibility considerations.)
- Mosley v. State, 968 S.W.2d 612 (Ark. 1998) (newly discovered information vs. fundamental error.)