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Keywords

jurisdictiontrialburden of proof
trial

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Carner v. State, 2018 Ark. 20, 535 S.W.3d 634

Facts

Adrian Louis Carner was convicted of first-degree murder in 2003. Following his conviction, he filed a pro se petition seeking to reinstate jurisdiction in the trial court to consider a writ of error coram nobis, claiming that the State failed to prove the elements of the offense and that there were errors in his trial. He also contended that the appellate courts did not conduct a proper review of his case and that the State violated Brady v. Maryland by referencing his prior record improperly.

Carner has not demonstrated in the petition that the writ should issue, the petition is denied.

Issue

Whether Carner's claims regarding the sufficiency of evidence and trial errors were cognizable in a petition for writ of error coram nobis.

Whether Carner's claims regarding the sufficiency of evidence and trial errors were cognizable in a petition for writ of error coram nobis.

Rule

A writ of error coram nobis is an extraordinary remedy available only under compelling circumstances to address fundamental errors, and challenges to the sufficiency of evidence or trial errors that could have been raised at trial are not cognizable in such proceedings.

A writ of error coram nobis is an extraordinarily rare remedy.

Analysis

The court determined that Carner's claims primarily focused on the sufficiency of the evidence presented at trial, which constitutes a direct attack on the judgment and is not permissible in a coram nobis proceeding. Additionally, the court noted that assertions of trial error that were or could have been raised at trial are outside the scope of coram nobis relief. The court emphasized that the petitioner bears the burden of demonstrating a fundamental error of fact extrinsic to the record, which Carner failed to do.

The court determined that Carner's claims primarily focused on the sufficiency of the evidence presented at trial, which constitutes a direct attack on the judgment and is not permissible in a coram nobis proceeding.

Conclusion

The Supreme Court denied Carner's petition for writ of error coram nobis, concluding that he did not demonstrate the necessary grounds for the writ.

Petition denied.

Who won?

The State prevailed in the case because the court found that Carner's claims were not cognizable in a coram nobis proceeding and that he failed to meet the burden of proof required for such a writ.

The State prevailed in the case because the court found that Carner's claims were not cognizable in a coram nobis proceeding.

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