Williams v. State
2017 Ark. 20
| Ark. | 2017Background
- Alvin Ray Williams was convicted of first-degree murder in 1994 and sentenced to life; conviction affirmed on direct appeal.
- After unsuccessful Rule 37 postconviction relief, Williams sought permission (granted by this court) to file a writ of error coram nobis in circuit court alleging a Brady violation based on an undisclosed witness statement supporting his self-defense theory.
- Williams filed the coram nobis petition in Pulaski County; the circuit court denied the petition and denied his motions for in forma pauperis status and appointment of counsel by brief, unelaborated orders.
- Williams moved for reconsideration; the circuit court again denied relief without findings or an evidentiary hearing, and Williams appealed the denials to this court.
- This court concluded the circuit court should have conducted further proceedings (discovery/evidentiary hearing) and entered findings; it reversed and remanded for an evidentiary hearing and directed the circuit court to enter findings.
- The court also granted Williams in forma pauperis status and appointed counsel (Lee D. Short). The decision produced concurring and dissenting opinions focusing on the role of "due diligence" in coram nobis proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the circuit court erred by denying coram nobis without a hearing or factual findings | Williams: Petition appeared meritorious; circuit court should allow discovery and an evidentiary hearing and make findings | State: Circuit court may deny for lack of diligence or on merits without further proceedings | Court reversed and remanded; directed an evidentiary hearing and entry of specific findings |
| Whether Williams demonstrated due diligence in seeking coram nobis relief | Williams: He acted with sufficient diligence; factual development required to resolve diligence and Brady issues | State: Williams delayed and failed to demonstrate due diligence; petition untimely and meritless | Court declined to resolve diligence as a bar on the record and ordered factual development at remand |
| Whether undisclosed witness statement constituted a Brady violation warranting relief | Williams: Statement was exculpatory and would have supported self-defense; nondisclosure was material | State: Williams has alleged but not proved the prosecution withheld the statement or that it was material | Court found the petition raised issues meriting an evidentiary hearing to determine Brady merits |
| Whether in forma pauperis status and counsel should be provided for coram nobis proceedings | Williams: Cannot proceed effectively without counsel and qualifies as indigent | State: No absolute right to counsel in postconviction matters; appointment discretionary | Court granted IFP status and appointed counsel (Lee D. Short) for circuit-court proceedings |
Key Cases Cited
- Williams v. State, 325 Ark. 432, 930 S.W.2d 297 (1996) (affirming Williams's conviction)
- Howard v. State, 2012 Ark. 177, 403 S.W.3d 38 (defines coram nobis standards and the requirement to show meritorious attack)
- Pitts v. State, 336 Ark. 580, 986 S.W.2d 407 (procedure for reinvesting jurisdiction in circuit court for coram nobis)
- State v. Larimore, 341 Ark. 397, 17 S.W.3d 87 (describes writ as addressed to trial court and purpose of coram nobis)
- Newman v. State, 2009 Ark. 539, 354 S.W.3d 61 (sets out due-diligence elements for coram nobis)
- Thomas v. State, 367 Ark. 478, 241 S.W.3d 247 (recognizes five-year delay can demonstrate lack of diligence)