Ronald Christopher Hayes v. State of Tennessee

Citation: Not availableDocket: M2016-01094-CCA-R3-ECN

Court: Court of Criminal Appeals of Tennessee; September 27, 2017; Tennessee; State Appellate Court

Original Court Document: View Document

SummaryOriginalCytator Case TreatmentBackward CitatorAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

Ronald Christopher Hayes, the Petitioner, entered a "best interest" plea to second degree murder in 2010, receiving a 25-year sentence after being indicted for felony murder and aggravated child abuse related to the death of his girlfriend’s infant. In April 2016, he filed a petition for a writ of error coram nobis, presenting newly discovered evidence through an affidavit from Nicole Crockett, which claimed that the victim's mother, Brandi Castle, had a history of child abuse and neglect, including injuries to another child. The trial court dismissed the petition as time-barred, stating that it was filed outside the one-year statute of limitations. Hayes contended the court erred in not tolling the statute, claiming the evidence was only discoverable in 2015. The Court of Criminal Appeals affirmed the trial court’s judgment, agreeing with the dismissal of the petition.

The trial court's dismissal of the Petitioner’s claim as untimely was upheld by the State, which argued that the grounds presented did not qualify as “newly discovered evidence” under Tennessee law. According to Tennessee Code Annotated section 40-26-105 (2012), a writ of error coram nobis is available to convicted defendants, but it requires that the defendant demonstrate they were not at fault for failing to present certain evidence at trial, potentially affecting the judgment. This writ is considered an extraordinary remedy with limited applicability, and its grant is subject to the discretion of the coram nobis court, reviewed for abuse of discretion.

Petitions for a writ must be filed within one year of the final judgment, which is defined as either thirty days after the judgment or after a ruling on any timely post-trial motions. In this case, since the judgment became final in May 2010 and the petition was filed in April 2016—over five years later—it was deemed untimely. Although the statute of limitations may be tolled for claims of actual innocence based on newly discovered evidence, the court must balance the petitioner’s right to a hearing against the State’s interest in addressing stale claims. 

The Burford rule outlines a three-step process for determining if due process requires tolling the statute, which includes examining when the limitations period began, whether the grounds arose after this period, and if strict adherence would preclude a reasonable opportunity to present the claim. Generally, claims must not have existed during the limitations period to qualify for such consideration. Discovery of a claim or ignorance of it does not create a “later-arising” claim.

Additionally, the writ of error coram nobis cannot be used to challenge guilty-pleaded convictions, as established in Frazier v. State, which clarified that the statute pertains only to newly discovered evidence related to matters litigated at trial.

The term “litigated on [or at] the trial” in criminal prosecutions is defined as a contested proceeding where evidence is submitted to a fact-finder for assessment under applicable law, leading to a verdict of guilt or acquittal. The Frazier court determined that a guilty plea is a non-adversarial proceeding, rendering the error coram nobis statute inapplicable. In this context, Alford pleas, where defendants plead guilty while maintaining innocence, are considered. The Supreme Court's ruling in North Carolina v. Alford allows such pleas if the defendant intelligently concludes that a guilty plea serves their interests.

Although Alford pleas may present a stronger public policy argument for seeking error coram nobis relief, the decision rests with the legislature, not the court. The court suggests that the same rationale applied in Frazier would exclude Alford pleas from error coram nobis relief due to their non-contested nature. The petitioner's affidavit does not qualify as newly discovered evidence because the evidence of M.R.C.’s abuse was not available at the time of the petitioner’s Alford plea; M.R.C. was born after the plea. Additionally, evidence related to the petitioner’s awareness of Ms. Castle’s parenting does not constitute new evidence or demonstrate actual innocence. Consequently, the court finds that due process does not necessitate tolling the statute of limitations, agreeing with the trial court's conclusion that the petition is untimely and affirming the denial of the writ of error coram nobis.