Williams v. State
2017 Ark. 313
| Ark. | 2017Background
- Fred Lee Williams filed a pro se petition for a writ of error coram nobis challenging his 2014 guilty plea to felon in possession of a firearm.
- Williams alleged the State violated Brady, suborned perjury, and breached a plea agreement by failing to disclose a witness statement (Varetta Butcher) and concealing testimony from another trial.
- The trial court dismissed the petition; Williams appealed the dismissal.
- The court treated the coram nobis petition as raising ineffective-assistance-of-counsel claims because Williams’ allegations centered on his counsel’s performance at plea and trial.
- The court found Williams failed to show his claims fit the narrow coram nobis grounds (insanity, coerced plea, material evidence withheld by prosecutor, or third-party confession) and that no Brady violation was shown because the Butcher statement appeared in a 2013 search-warrant affidavit.
- The court affirmed dismissal, holding actual-innocence and ordinary sufficiency challenges are not cognizable in coram nobis and coercion required threats/duress not present here.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether withheld evidence (Brady) warrants coram nobis relief | Williams: State failed to disclose Butcher statement and concealed witness testimony, affecting plea | State: Evidence was discoverable (referenced in 2013 affidavit); no suppression by State | No Brady violation shown; coram nobis relief denied |
| Whether petition properly treated as ineffective-assistance-of-counsel claim | Williams: Framed claims as Brady/innocence, not IAC | State/Trial court: Allegations actually attack counsel’s performance at plea/trial; IAC is Rule 37.1 matter | Court permissibly treated petition as raising IAC-type claims and noted coram nobis is not a substitute for Rule 37.1 |
| Whether plea was coerced such that coram nobis is available | Williams: State’s actions pressured him into pleading guilty | State: No coercion by fear, duress, or threats as required for coram nobis | Plea not shown to be product of coercion; coram nobis not available on this ground |
| Whether claim of actual innocence can be remedied by coram nobis | Williams: He is actually innocent of the offense he pleaded to | State: Actual-innocence/sufficiency is a direct attack on the judgment, not coram nobis relief | Actual-innocence claim is a direct challenge to judgment and not cognizable in coram nobis |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose materially exculpatory or impeaching evidence)
- Strickler v. Greene, 527 U.S. 263 (1999) (elements and prejudice standard for Brady claims)
- State v. Larimore, 341 Ark. 397 (2000) (four narrow categories for coram nobis relief)
- State v. Tejeda–Acosta, 427 S.W.3d 673 (Ark. 2013) (affirming standard of review for coram nobis denials)
- Williams v. State, 516 S.W.3d 722 (Ark. 2017) (prior coram nobis petition by Williams; no Brady violation found)
- Nelson v. State, 431 S.W.3d 852 (Ark. 2014) (coram nobis is not a substitute for Rule 37.1 ineffective-assistance proceedings)
- Roberts v. State, 425 S.W.3d 771 (Ark. 2013) (defendant must show fundamental error extrinsic to record concealed from defense)
- Thacker v. State, 500 S.W.3d 736 (Ark. 2016) (coram nobis coercion requires fear, duress, or threats)
- Scott v. State, 520 S.W.3d 262 (Ark. 2017) (actual-innocence claim is a direct attack on judgment and not cognizable in coram nobis)