Randall Thomas McArty v. State of Arkansas

Summary

The Arkansas Supreme Court denied Randall Thomas McArty’s fourth pro se petition to reinvest jurisdiction in the circuit court to consider a writ of error coram nobis, as well as his motion for appointment of counsel. McArty alleged that the State withheld portions of the criminal case file and medical examiner’s report in violation of Brady v. Maryland. The court held that he failed to establish that material evidence was withheld, that a Brady violation occurred, or that the alleged information created a reasonable probability of a different result.

Holdings

1. A petitioner must demonstrate a fundamental error of fact extrinsic to the record and overcome the strong presumption that the criminal judgment is valid before the Supreme Court will reinvest the trial court with jurisdiction to consider coram nobis relief.
2. A petitioner alleging a Brady violation in a coram nobis proceeding must show that the evidence was favorable, that the State suppressed it, and that prejudice resulted; the petitioner must also establish that the material was available to the State before trial and was not possessed by the defense.
3. A claim challenging the sufficiency of the evidence is not a ground for a writ of error coram nobis.
4. The motion for appointment of counsel was denied because McArty failed to establish sufficient grounds to proceed with a coram nobis petition.

Questions Presented

1. Whether McArty established grounds for the Supreme Court of Arkansas to reinvest the circuit court with jurisdiction to consider a writ of error coram nobis based on an alleged Brady violation.
2. Whether the newly obtained criminal-file and medical-examiner materials demonstrated a reasonable probability that disclosure at trial would have changed the judgment.
3. Whether McArty was entitled to appointment of counsel for the coram nobis proceeding.

Disposition

other