Danny Lee Ashley v. State of Arkansas

2021 Ark. 89
CourtSupreme Court of Arkansas
DecidedApril 22, 2021
StatusPublished
Cited by2 cases

This text of 2021 Ark. 89 (Danny Lee Ashley v. State of Arkansas) is published on Counsel Stack Legal Research, covering Supreme Court of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Danny Lee Ashley v. State of Arkansas, 2021 Ark. 89 (Ark. 2021).

Opinion

Cite as 2021 Ark. 89 SUPREME COURT OF ARKANSAS No. CR-11-613

Opinion Delivered: April 22, 2021 DANNY LEE ASHLEY PRO SE PETITION TO REINVEST PETITIONER JURISDICTION IN THE TRIAL V. COURT TO CONSIDER A PETITION FOR WRIT OF ERROR CORAM STATE OF ARKANSAS NOBIS AND FOR CLARIFICATION OF CERTAIN DATES RESPONDENT [GRANT COUNTY CIRCUIT COURT, NO. 27CR-10-22]

PETITION DENIED.

COURTNEY RAE HUDSON, Associate Justice

Petitioner Danny Lee Ashley was convicted by a Grant County jury of possession of

drug paraphernalia with intent to manufacture methamphetamine, a class B felony, and

possession of a controlled substance (methamphetamine), a class C felony, for which he was

sentenced to an aggregate term of 240 months’ imprisonment in the Arkansas Division of

Correction. The Arkansas Court of Appeals affirmed Ashley’s conviction and sentence.

Ashley v. State, 2012 Ark. App. 131, 388 S.W.3d 914. Ashley brings this pro se petition to

reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and

for clarification of certain dates in which he contends that the State withheld material

evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963), and that he is being denied due process of law and being subjected to cruel and unusual punishment. Because none of

Ashley’s claims establish a ground for the writ, the petition is denied.

The petition for leave to proceed in the trial court is necessary because the trial court

can entertain a petition for writ of error coram nobis after a judgment has been affirmed on

appeal only after we grant permission. Newman v. State, 2009 Ark. 539, 354 S.W.3d 61. A

writ of error coram nobis is an extraordinarily rare remedy. State v. Larimore, 341 Ark. 397,

17 S.W.3d 87 (2000). Coram nobis proceedings are attended by a strong presumption that

the judgment of conviction is valid. Green v. State, 2016 Ark. 386, 502 S.W.3d 524. The

function of the writ is to secure relief from a judgment rendered while there existed some

fact that would have prevented its rendition had it been known to the trial court and which,

through no negligence or fault of the defendant, was not brought forward before rendition

of the judgment. Newman, 2009 Ark. 539, 354 S.W.3d 61. The petitioner has the burden of

demonstrating a fundamental error of fact extrinsic to the record. Roberts v. State, 2013 Ark.

56, 425 S.W.3d 771. We are not required to accept the allegations in a petition for writ of

error coram nobis at face value. Jackson v. State, 2017 Ark. 195, 520 S.W.3d 242.

In making his first claim to reinvest jurisdiction in the trial court, Ashley contends

“he was prejudiced because he was convicted of a crime that he was not guilty of committing”

and that the trial court “exceeded it subject-matter jurisdiction and should not have entered

a judgment of conviction for a crime not charged.” Ashley argues that the conviction for

2 possession of a controlled substance should be reversed and dismissed.1 Ashley’s challenge

fails to establish that the trial court lacked authority over the criminal matter.

Although Ashley’s argument is framed as a challenge to the subject-matter jurisdiction

of the trial court, his argument is nothing more than assertions of a defective information

and trial error and restates the arguments he made on direct appeal––that the “material

variance of the criminal information that charged him with possession of methamphetamine

and the State’s evidence of possession of amphetamine was unduly prejudicial to his defense

[and that] the State should have amended the information prior to trial to reflect the drug

at issue was amphetamine.” Ashley, 2012 Ark. App. 131, at 8, 388 S.W.3d at 920. The court

of appeals determined that, notwithstanding the State’s failure to amend the information,

Ashley failed to move for a directed verdict on that ground. And even though the chemist

testified that the substance was amphetamine, Ashley testified that it was methamphetamine,

meaning the jury was free to believe Ashley and convict him on the basis of his testimony.

Id. Ashley’s claim that the trial court lacked authority to impose a sentence of imprisonment

with respect to his conviction for possession of a controlled substance lacks a factual basis to

support a finding that the criminal information was defective—as he was provided notice of

1 The writ will lie only to correct errors of fact and not errors of law, and the appropriate remedy under the writ is a new trial. Hallman v. State, 2018 Ark. 336, at 3, 561 S.W.3d 305, 307 (citing Smith v. State, 200 Ark. 767, 140 S.W.2d 675 (1940)).

3 the charge for which he was convicted2—and does not therefore raise a jurisdictional issue

concerning the judgment. See Rainer v. State, 2019 Ark. 42, 566 S.W.3d 462.

Ashley next claims that he is entitled to the writ because the State committed a Brady

violation. While a Brady violation comes within the purview of coram nobis relief, the fact

that a petitioner alleges a Brady violation is not, in itself, sufficient to provide a basis for the

writ. Wallace v. State, 2018 Ark. 164, 545 S.W.3d 767. It is a violation of Brady and a ground

for the writ if the defense was prejudiced because the State wrongfully withheld evidence

from the defense prior to trial. Mosley v. State, 2018 Ark. 152, 544 S.W.3d 55. The Court

held in Brady that “the suppression by the prosecution of evidence favorable to an accused

upon request violates due process where the evidence is material to guilt or punishment,

irrespective of the good faith or bad faith of the prosecution.” 373 U.S. at 87. There are

three elements of a Brady violation: (1) the evidence at issue must be favorable to the accused,

either because it is exculpatory or because it is impeaching; (2) the evidence must have been

suppressed by the State, either willfully or inadvertently; (3) prejudice must have ensued.

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

Ashley contends that a Brady violation occurred when the State failed to disclose,

prior to trial, that the Arkansas State Crime Laboratory chemist determined—and the lab

report revealed—that the substance found on Ashley was amphetamine and not

2 The jury found Ashley guilty of the lesser-included offense of possession of a controlled substance (methamphetamine) in lieu of the charged offense, possession of a controlled substance with intent to deliver (methamphetamine).

4 methamphetamine and that the State was obligated to disclose to the defense that the

substance tested negative for methamphetamine, since he was charged with possession of a

controlled substance (methamphetamine) with intent to manufacture. Although Ashley’s

argument centers on the State’s alleged failure to disclose the crime-lab report prior to trial,

the report was admitted at trial, and the crime-lab chemist testified at trial. When a petitioner

offers nothing to show that information was concealed from the defense, and the issue could

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