Williams v. State
2017 Ark. 145
| Ark. | 2017Background
- Fred L. Williams was convicted of first-degree murder and abuse of a corpse in 2014 and sentenced to life as a habitual offender; this Court affirmed on direct appeal (Williams v. State, 2015 Ark. 316).
- Williams filed a pro se petition asking this Court to reinvest jurisdiction in the trial court so he could pursue a writ of error coram nobis challenging his conviction.
- He principally alleges the State suppressed exculpatory evidence (Brady claim) tied to the victim’s cell-phone records (State’s Exhibit 3) and omitted or withheld statements and forensic information that would have aided the defense.
- Trial evidence included Williams’s post-arrest statements admitting he and the victim engaged in sexual activity involving restraint and a plastic bag, and that he buried her after she became unresponsive; medical evidence showed death by asphyxia by undetermined means.
- Williams also raised alleged contradictions in a witness’s statements (Varetta Butcher), argued DNA under the victim’s fingernails implicated another person, complained about alleged suppressed autopsy information, and alleged ineffective assistance of counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether court should reinvest jurisdiction to consider coram nobis petition | Williams: State suppressed exculpatory evidence warranting coram nobis review | State: No coram nobis ground shown; direct appeal already resolved sufficiency and trial errors | Denied — petitioner failed to show basis for reinvestment |
| Whether suppression of cell-phone records (State’s Exhibit 3) violated Brady | Williams: Records contained exculpatory/impeaching information and were withheld or misrepresented, affecting outcome | State: No specific evidence shown to have been concealed; no reasonable probability of different result | Denied — conclusory allegations, no showing of suppressed material evidence |
| Whether alleged withheld witness statements and contradictions (Butcher) created Brady claim | Williams: Butcher’s unproduced/contradictory statements would impeach State’s case | State: Allegations are trial-error/credibility disputes that do not show suppressed Brady material | Denied — amounts to trial-error/credibility dispute, not coram nobis relief |
| Whether ineffective assistance of counsel can be raised via coram nobis | Williams: Counsel failed to investigate or present favorable evidence | State: IAC claims must be raised under Rule 37.1, not coram nobis | Denied — coram nobis is not the vehicle for IAC claims; must use postconviction rule |
Key Cases Cited
- Newman v. State, 2009 Ark. 539 (coram nobis requires this Court’s permission after affirmation on appeal)
- State v. Larimore, 341 Ark. 397 (coram nobis is an extraordinary remedy with a strong presumption of validity)
- Williams v. State, 2015 Ark. 316 (direct-appeal decision affirming convictions)
- Brady v. Maryland, 373 U.S. 83 (suppression of favorable material evidence violates due process)
- Strickler v. Greene, 527 U.S. 263 (Brady materiality standard: reasonable probability of different result)
- United States v. Bagley, 473 U.S. 667 (impeaching evidence materiality standard)