Summary
The Tennessee Supreme Court held that Ricky Harris’s petition for a writ of error coram nobis was barred by the one-year statute of limitations. The Court concluded that his six-year delay concerning alibi evidence and twenty-one-month delay concerning third-party confession evidence were unreasonable as a matter of law, so due process did not require tolling the limitations period. The Court reversed the Court of Criminal Appeals and reinstated the trial court’s dismissal.
Topics
Practice areas
Questions Presented
- Whether Harris's petition for writ of error coram nobis was barred by Tennessee's one-year statute of limitations.
- Whether due process required tolling the one-year limitations period for Harris's claims based on allegedly later-arising evidence of actual innocence.
- Whether the Court of Criminal Appeals erred in reversing the trial court's summary dismissal and remanding for an evidentiary hearing.
Holdings
- Harris's delay in seeking coram nobis relief—approximately six years as to the alibi evidence and approximately twenty-one months as to the third-party confession evidence—was unreasonable as a matter of law under the circumstances, so the petition was barred by the one-year statute of limitations.
- Due process did not require tolling the statute of limitations because Harris had a reasonable opportunity to present his coram nobis claims after the asserted grounds for relief became available.
- The Court of Criminal Appeals erred in reversing the summary dismissal and remanding for further proceedings because the pleadings, viewed in the light most favorable to Harris, did not establish a legal basis for overcoming the limitations bar.
Key quotations
“The time within which Mr. Harris filed his petition for writ of error coram nobis exceeds the reasonable opportunity afforded by due process.” (at 7)
“Mr. Harris’s delay in seeking coram nobis relief—six years with respect to the alibi evidence and twenty-one months with respect to the third-party confession—is unreasonable under the circumstances of this case.” (at 7)
“Accordingly, we reverse the judgment of the Court of Criminal Appeals and reinstate the judgment of the trial court dismissing the petition.” (at 8)
Factual background
Harris was convicted of first degree murder in 1988 and sentenced to life imprisonment. He later relied on purportedly exculpatory evidence involving an alibi witness, Corrine Hampton, and letters from a person identified as Bill who allegedly confessed to the murder and absolved Harris. Harris asserted that he did not learn the exculpatory nature of the Hampton evidence until 1998 and did not obtain handwriting-expert evidence identifying the author of the Bill letters until June 2002, but he did not file his coram nobis petition until March 11, 2004.
Procedural history
Harris was convicted of first degree murder and his conviction and sentence were affirmed on direct appeal. His post-conviction proceedings were also unsuccessful. After the trial court denied a motion to reopen post-conviction proceedings, the Court of Criminal Appeals sua sponte treated the motion as a coram nobis petition; the Tennessee Supreme Court previously held that treatment erroneous. Harris later filed a separate coram nobis petition based on purportedly newly discovered alibi and third-party-confession evidence. The trial court summarily dismissed the petition as barred by the statute of limitations, the Court of Criminal Appeals reversed and remanded, and the Tennessee Supreme Court reversed the intermediate appellate court and reinstated the dismissal.