Weekly v. State
2014 Ark. 365
| Ark. | 2014Background
- Charles Weekly pled guilty in 1986 to rape and kidnapping in two Pulaski County cases, receiving life terms for rape and ten years for kidnapping in each case.
- In 2013, Weekly filed a pro se coram nobis petition alleging coercion of confessions, coerced plea, withheld statements, and temporary insanity at the time of the plea.
- The trial court denied the coram nobis petition as conclusory and based on lack of due diligence, noting filing occurred nearly 27 years after judgment.
- The writ of error coram nobis is reviewed for abuse of discretion and is available only in limited, fundamental-error scenarios.
- The court emphasizes coram nobis relief is extraordinary and requires showing facts extrinsic to the record, with due diligence.
- Appellate review affirms the denial, finding no evidentiary support for claims, no proven Brady violation, no coercion or insanity supporting relief, and lack of due diligence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred by denying an evidentiary hearing | Weekly argues for a hearing on the coram nobis petition | State contends petition lacks factual substantiation and due diligence | Affirmed; no hearing required due to lack of merit and diligence |
| Brady violation due to suppressed pretrial statements and reports | Weekly claims exculpatory material was withheld | State denies suppression and materiality | Denied; petitioner failed to show a reasonable probability the outcome would differ |
| Coercion or insanity as grounds for relief | Confessions and plea were coerced and insanity affected plea | No substantiated coercion or insanity shown | Denied; allegations not supported; delay and lack of substantiation foreclose relief |
| Due diligence in filing coram nobis petition | Weekly acted with due diligence | No due diligence shown given 27-year delay | Denied; lack of explanation for delay and absence of timely action |
Key Cases Cited
- Wright v. State, 2014 Ark. 25 (Ark. 2014) (abuse-of-discretion standard for coram nobis; strong presumption of validity)
- McClure v. State, 2013 Ark. 306 (Ark. 2013) (due diligence required; abuse-of-discretion review)
- Lee v. State, 2012 Ark. 401 (Ark. 2012) (strong presumption of conviction validity; coram nobis limits)
- Cromeans v. State, 2013 Ark. 273 (Ark. 2013) (coram-nobis radars for extraordinary relief; rarity emphasized)
- Greene v. State, 2013 Ark. 251 (Ark. 2013) (four categories for relief under coram nobis)
- Pitts v. State, 2014 Ark. 132 (Ark. 2014) (due diligence requirement; sustained denial without merit)