Wilson v. State
2014 Ark. 273
| Ark. | 2014Background
- In 2010, Wilson was convicted by a jury of delivery of a controlled substance and sentenced as a habitual offender to 480 months; an additional 240 months was suspended.
- The Arkansas Court of Appeals affirmed the conviction in Wilson v. State, 2011 Ark. App. 382.
- Wilson later sought postconviction relief under Rule 37.1, which the trial court denied; an appeal to this court was dismissed for untimeliness.
- Wilson filed in this court a petition to reinvest jurisdiction in the trial court to pursue a writ of error coram nobis, along with requests for a writ of certiorari and a temporary restraining order.
- The court held there is no merit to reinvest jurisdiction or the ancillary requests, and denied the petition and requests.
- A writ of error coram nobis is available only in extraordinary circumstances and for narrow categories of errors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether coram nobis is proper to address trial errors | Wilson asserts trial errors merit coram-nobis relief. | State argues coram-nobis is unavailable for routine trial-errors claims. | No; coram-nobis does not cover ordinary trial errors. |
| Whether the case falls within one of the four coram nobis categories | Wilson contends error fell within withheld material evidence. | State limits coram-nobis to specific categories (insanity, coerced plea, suppressed evidence, third-party confession). | Only potential fit was withheld material evidence; others do not qualify. |
| Whether the alleged Brady violation supports relief | Tapes were withheld or not fully disclosed, affecting outcome. | No demonstrated withholding meeting Brady's materiality and prejudice standard. | Insufficient showing of a favorable, suppressed, material, and prejudicial Brady violation. |
| Whether the petition warrants restraining orders or certiorari relief | Petition seeks extraordinary relief to obtain evidence. | Requests are unsupported and improper in coram nobis context. | Denied; relief not warranted. |
| Whether jurisdiction should be reinvested to allow coram nobis filing | Reinvestment needed to pursue coram nobis after affirmation on appeal. | Reinvestment denied under precedents requiring permission for post-affirmance coram nobis. | Denied. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (US 1963) (favorable evidence suppression violates due process if material)
- Strickler v. Greene, 527 U.S. 263 (US 1999) (three elements of true Brady violation; materiality and prejudice)
- U.S. v. Bagley, 473 U.S. 667 (US 1985) (material evidence standard for Brady)
- Charland v. State, 2013 Ark. 452 (Ark. 2013) (coram-nobis available for fundamental extrinsic errors)
- Cromeans v. State, 2013 Ark. 273 (Ark. 2013) (categories of coram nobis relief; rarity of availability)
- Pitts v. State, 336 Ark. 580 (Ark. 1999) (Brady-related coram-nobis relief for suppressed evidence)
- Wright v. State, 2014 Ark. 25 (Ark. 2014) (burden to show fundamental error in coram-nobis)
- Hooper v. State, 2014 Ark. 16 (Ark. 2014) (permission required to pursue coram-nobis after affirmance)
- Burks v. State, 2013 Ark. 188 (Ark. 2013) (per curiam; coram-nobis scope)
- Cloird v. State, 2011 Ark. 303 (Ark. 2011) (coram-nobis proceedings characteristics)