Summary
The Supreme Court of Arkansas denied Fred L. Williams’s pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. Williams alleged Brady violations involving cell-phone records, witness statements, DNA evidence, autopsy evidence, prosecutorial misconduct, and ineffective assistance of counsel. The court held that he failed to establish a Brady violation and that claims concerning trial error, sufficiency of the evidence, and ineffective assistance of counsel were not cognizable in coram nobis proceedings.
Topics
Practice areas
Questions Presented
- Whether Williams demonstrated a Brady violation sufficient to warrant permission to pursue a writ of error coram nobis based on alleged suppression of cell-phone records and other evidence.
- Whether claims concerning the sufficiency of the evidence, trial error, prosecutorial misconduct, or alleged perjury were cognizable in a coram nobis proceeding.
- Whether alleged failures by trial counsel to investigate or present favorable evidence could support coram nobis relief.
Holdings
- Williams failed to establish a Brady violation because he did not show that specific favorable evidence was suppressed from the defense or that disclosure of the asserted information created a reasonable probability of a different trial outcome.
- Claims attacking the sufficiency of the evidence or alleging trial error, including constitutional trial error, are outside the scope of coram nobis proceedings and cannot support issuance of the writ.
- Ineffective-assistance-of-counsel claims are not cognizable in coram nobis proceedings and must instead be raised under Arkansas Rule of Criminal Procedure 37.1.
Key quotations
“A writ of error coram nobis is an extraordinarily rare remedy.” (at 1)
“The function of the writ is to secure relief from a judgment rendered while there existed some fact that would have prevented its rendition had it been known to the trial court and which, through no negligence or fault of the defendant, was not brought forward before rendition of the judgment.” (at 1-2)
“There are three elements of a Brady violation: (1) the evidence at issue must be favorable to the accused, either because it is exculpatory or because it is impeaching; (2) the evidence must have been suppressed by the State, either willfully or inadvertently; (3) prejudice must have ensued.” (at 2)
“Allegations of trial error, even those of constitutional dimension, do not provide a ground to grant a writ of error coram nobis.” (at 6)
Factual background
Williams was convicted of killing Tangela Walton during a sexual encounter and of abusing her corpse by disposing of her body. At trial, the State introduced evidence including Walton's cell-phone records, witness testimony, forensic evidence, and Williams's statements concerning Walton's death and burial. In his coram nobis petition, Williams alleged that the State suppressed or misused exculpatory and impeachment evidence, including cell-phone information, witness statements, DNA evidence, autopsy information, and evidence relating to alleged prosecutorial misconduct.
Procedural history
Williams was convicted in 2014 of first-degree murder and abuse of a corpse and received an aggregate life sentence as a habitual offender. The Supreme Court of Arkansas affirmed the convictions and denied rehearing. Williams then filed a pro se petition seeking leave to pursue coram nobis relief in the trial court; the Supreme Court denied the petition.