Wright v. State
2014 Ark. 25
| Ark. | 2014Background
- In 1992 Donald R. Wright pleaded guilty to multiple counts of aggravated robbery and theft and received an aggregate life sentence.
- In 2011 Wright filed a pro se petition for writ of error coram nobis, claiming (1) the prosecution withheld information about his mental competence, (2) the trial court failed to hold a competency hearing before accepting a coerced plea, and (3) he received ineffective assistance of counsel.
- The trial court denied the petition, finding the claims meritless or not cognizable in coram-nobis, and that Wright failed to exercise due diligence in bringing the claim nearly twenty years after judgment.
- The court applied the coram-nobis standard: relief is extraordinary, requires an extrinsic, fundamental factual error unknown at trial, and is limited to narrow categories (insanity at trial, coerced plea, suppressed material evidence, third-party confession).
- The court found Wright failed to show a Brady violation or any extrinsic fact unknown at trial, that ineffective-assistance claims belong in a Rule 37.1 postconviction proceeding, and that Wright lacked due diligence in delaying relief.
Issues
| Issue | Wright's Argument | State's Argument | Held |
|---|---|---|---|
| Brady/suppression of exculpatory evidence | Prosecution withheld information about his mental competence and evaluations that would have shown incompetence/diminished capacity | No specific favorable evidence was identified as concealed; Wright was aware of his history and could have presented it at trial | Denied — Wright failed to identify suppressed, material evidence unknown at trial and thus failed to meet Brady/coram-nobis burden |
| Voluntariness/coerced plea | Plea was coerced / involuntary because competency was not established and advice was erroneous | Claim could have been raised at trial or in a timely Rule 37.1 petition; no factual showing of coercion as defined for coram-nobis | Denied — no coercion shown within coram-nobis scope; voluntariness/ineffective-assistance claims belong in Rule 37.1 proceedings |
| Ineffective assistance of counsel | Counsel failed to discover or present his mental-health and academic records, rendering assistance ineffective | Ineffective-assistance claims are outside coram-nobis and must be raised under Rule 37.1 | Denied — coram-nobis is not a substitute for Rule 37.1; claim not cognizable in coram-nobis |
| Due diligence / timeliness | (Implicit) Delay justified by newly discovered facts about mental condition | Petition filed ~20 years after judgment; Wright failed to show facts were unknown at trial or that he acted promptly after discovery | Denied — Wright did not satisfy the sequential due-diligence requirements for coram-nobis relief |
Key Cases Cited
- Pitts v. State, 336 Ark. 580, 986 S.W.2d 407 (Ark. 1999) (suppression of material exculpatory evidence can warrant coram-nobis relief)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecutorial suppression of favorable, material evidence violates due process)
- Strickler v. Greene, 527 U.S. 263 (1999) (defines Brady materiality and elements of a Brady claim)
- United States v. Bagley, 473 U.S. 667 (1985) (reasonable-probability standard for impeachment evidence under Brady)
- Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel)
- Hardwick v. State, 220 Ark. 464, 248 S.W.2d 377 (Ark. 1952) (example of coerced-plea coram-nobis relief)