Grant v. State

Summary

The Arkansas Supreme Court denied Abraham Grant’s pro se petition for permission to pursue a writ of error coram nobis in the trial court following his capital-murder and first-degree-battery convictions. The court held that Grant failed to show suppressed material evidence, and that his ineffective-assistance and sufficiency-of-the-evidence claims were not cognizable in coram nobis proceedings. The court also denied his requests for copies at public expense and deemed his motion to disqualify the trial judge moot.

Holdings

1. Grant failed to show good cause, a meritorious claim, or compelling circumstances warranting permission to proceed in the trial court with a petition for writ of error coram nobis.
2. The alleged failure to provide a bill of particulars did not establish a Brady violation or a basis for coram nobis relief because Grant did not show that he requested a bill of particulars or that the State suppressed specific favorable evidence.
3. Ineffective-assistance claims are outside the scope of coram nobis proceedings and must instead be brought under Arkansas Rule of Criminal Procedure 37.1(a).
4. Any challenge to the sufficiency of the evidence was a direct attack on the conviction that had to be raised at trial and on direct appeal, not through coram nobis.
5. Grant was not entitled to photocopies of the filings at public expense because he failed to demonstrate a compelling need for specific documentary evidence supporting a postconviction allegation.

Questions Presented

1. Whether Grant demonstrated a meritorious and compelling ground warranting permission to proceed in the circuit court with a petition for writ of error coram nobis.
2. Whether the alleged failure to provide a bill of particulars established suppression of material exculpatory evidence under Brady.
3. Whether allegations concerning ineffective assistance of counsel could be pursued through coram nobis proceedings.
4. Whether Grant was entitled to photocopies of filings at public expense.
5. Whether the motion to disqualify the trial judge remained justiciable after denial of permission to proceed.

Disposition

writ_denied