William Paul Eblen v. State of Tennessee

Citation: Not availableDocket: E2012-01117-CCA-R3-CD

Court: Court of Criminal Appeals of Tennessee; August 28, 2013; Tennessee; State Appellate Court

Original Court Document: View Document

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William Paul Eblen appeals the Knox County Criminal Court's denial of his petition for writ of error coram nobis, arguing that the court incorrectly found the testimony of two witnesses, who claimed the victim recanted her allegations, to be not credible. The appeal stems from Eblen's 2001 conviction for two counts of aggravated rape and one count of aggravated kidnapping, resulting in a 24-year sentence. 

At trial, the victim described an incident on August 31, 1998, where Eblen entered her car at gunpoint, forced her to a secluded location, and assaulted her both vaginally and anally, inflicting physical injuries. A friend of the victim corroborated her account, witnessing her emotional state and physical injuries shortly after the assault. Police officers observed additional injuries consistent with an assault, and medical examination revealed trauma corroborating the victim's testimony, including DNA evidence linking Eblen to the crime. 

Eblen claimed during the trial that the sexual encounter was consensual and denied understanding why the victim would lie. The court ultimately affirmed the coram nobis court's judgment, dismissing Eblen's appeal.

The Petitioner maintained that he engaged only in vaginal intercourse with the victim and was unaware of any injuries to her rectal area. His counsel suggested that the victim's facial injuries were inflicted by her boyfriend the night before the alleged assault. A police officer testified to a domestic call responding to the victim, who reported being hit by her boyfriend and had a split lip; however, the Petitioner claimed he noticed no injuries and that the victim did not complain about her lip or have a torn dress when he left her.

Before appealing his convictions, the Petitioner filed a writ of error coram nobis, asserting that the victim had confided in three individuals that he did not rape her. At the hearing, two of the victim’s ex-boyfriends testified that she admitted to lying about the rape due to fear of her boyfriend. Both men revealed their knowledge of her statements only after being incarcerated with the Petitioner. The victim testified at the hearing, denying the allegations made by the witnesses and reaffirming that the Petitioner raped her. The trial court found the witnesses not credible, emphasizing their relationship with the victim and the timing of their testimonies, and concluded that the evidence supported the victim's claims. The Petitioner’s convictions were upheld on direct appeal, with the court finding the evidence of guilt overwhelming and affirming the trial court’s denial of the writ.

On May 5, 2011, the Petitioner submitted a second writ of error coram nobis, claiming that two individuals, the victim’s ex-boyfriend Terry Norris and her brother B.P., had recently asserted that the victim had falsely accused him of rape. The coram nobis court allowed a hearing, where both men testified, but the victim did not appear. B.P. claimed the victim had expressed, during a party, that the Petitioner did not rape her and that she fabricated the accusation out of fear of Norris, who had allegedly assaulted her upon discovering her consensual encounter with the Petitioner. B.P. recounted that the victim's false claim was a desperate response to prevent further violence from Norris.

B.P. testified that he was unaware of how Mr. Norris learned about the sexual encounter between the victim and the Petitioner and admitted he did not disclose this information to anyone until after being incarcerated with the Petitioner. He communicated with the Petitioner in the prison yard, where Mr. Norris was present, and claimed to have had only one conversation about the incident. The Petitioner requested an affidavit, which B.P. initially wrote but later clarified that the legal clerk rephrased his outline into the final document. B.P. acknowledged discrepancies in the affidavit, including incorrect details about the timing of conversations and the victim's account of the events. He also revealed his criminal history and admitted to being out of touch with the victim for years, leading to limited knowledge about the alleged rape.

Mr. Norris denied hitting the victim on the night of the alleged rape and suggested her injuries resulted from a fall the previous night. He described their relationship as merely friendship and recounted a conversation where the victim expressed guilt over having someone imprisoned unjustly. He claimed that the victim indicated her interest in the Petitioner and that her allegation of rape was a spontaneous reaction in a moment of distress. Mr. Norris also stated he did not report the victim's comments until after his imprisonment with the Petitioner and acknowledged inconsistencies in his own affidavit. He maintained that he had no motive to harm the victim.

In 2001, the Petitioner was arrested and convicted of assault and aggravated burglary against the victim. The coram nobis court denied the Petitioner’s petition after reviewing trial transcripts, concluding that witness testimonies were not credible, particularly as they were convicted felons who only came forward after being incarcerated with the Petitioner. The court found their accounts inconsistent with trial evidence, noting that the victim had reported the alleged rape to a friend before informing Mr. Norris, and that there was no proof Mr. Norris was present when the victim returned home. The victim's injuries were also deemed recent and indicative of trauma.

The Petitioner is appealing this decision, arguing that new evidence suggesting the victim recanted her allegations is trustworthy and could have influenced the jury's decision. The State counters that the claim should be barred by the statute of limitations and supports the coram nobis court's assessment of witness credibility. A writ of error coram nobis is an extraordinary remedy for newly discovered evidence that could have affected the trial outcome, requiring the court to discern whether such evidence would have led to a different judgment. The decision to grant or deny this writ is at the trial court's discretion, which can be deemed an abuse if it misapplies legal standards or makes unreasonable decisions based on evidence.

The petition must be filed within one year of the trial court's final judgment, with tolling of the limitations period allowed only under due process concerns. Courts must balance the petitioner's right to a hearing against the State's interest in preventing stale claims by assessing when the limitations period began, whether new grounds for relief arose after that period, and if strict application of the limitations would unjustly deny the petitioner a chance to present their claim. In this case, the limitations period began when the trial court denied the Petitioner’s motion for a new trial in 2002, while the testimonies from B.P. and Mr. Norris regarding the victim's alleged statements emerged only in 2010.

A strict application of the statute of limitations could deny the Petitioner a fair opportunity to present his claim. Although the State contends that the Petitioner’s claim is barred due to a thirteen-month delay in filing after his conversation with Mr. Norris, prior case law indicates that such a delay does not inherently violate due process. The coram nobis court found that due process tolled the statute of limitations, supporting the notion that recanted testimony can be considered newly discovered evidence for a writ of error coram nobis. However, specific criteria must be met for newly discovered recanted testimony to justify a new trial: the trial court must find the original testimony false, the defendant must demonstrate due diligence or surprise regarding the false testimony, and the jury's verdict may have differed had the truth been revealed.

In this case, the trial and coram nobis courts determined there was insufficient evidence to support claims that the victim's trial testimony was false and the witnesses’ claims were credible. The evidence corroborated the victim's account, including medical findings consistent with rape and discrepancies in the testimonies of B.P. and Mr. Norris, who were both convicted felons with inconsistent statements. Ultimately, the coram nobis court did not abuse its discretion in denying the relief sought, leading to the affirmation of its judgment.