Thacker v. State

Summary

The Arkansas Supreme Court affirmed the denial of Elvis Thacker’s petition for a writ of error coram nobis. The court held that undisclosed police videos were not material to Thacker’s self-defense or suppression arguments and that his allegations of a coerced guilty plea were insufficient and untimely. The court also declined to review his actual-innocence claim because the circuit court had not ruled on it; two justices dissented regarding the need for an evidentiary hearing.

Holdings

1. The circuit court did not abuse its discretion in concluding that neither video was material to the Arkansas charges or sufficient to establish a Brady violation. The Taser video was only a limited recording of events immediately before entry, and the body-camera video was recorded after the arrest-related events and concerned statements relating to the Oklahoma investigation.
2. The circuit court did not abuse its discretion by denying coram nobis relief on the coerced-plea claim because the allegations were unsubstantiated, contradicted by the evidence, noncognizable in coram nobis proceedings, or brought after an unjustified four-year delay.
3. The actual-innocence claim was not reviewable because the circuit court did not rule on it.
4. The majority affirmed the denial without a hearing, concluding that Thacker had not developed the argument or provided appropriate authority; the dissent disagreed and would have required a hearing because the petition was not clearly meritless.

Questions Presented

1. Whether the circuit court abused its discretion by denying coram nobis relief based on allegedly suppressed video evidence under Brady v. Maryland.
2. Whether the circuit court abused its discretion by denying coram nobis relief based on an allegedly coerced guilty plea.
3. Whether the court could review Thacker's actual-innocence claim when the circuit court had not ruled on that issue.
4. Whether the circuit court erred by denying the coram nobis petition without a hearing.

Disposition

affirmed