Frazier v. State
Annotate this CasePetitioner pleaded guilty to second degree murder and was sentenced to twenty-five years in prison. Petitioner later filed this petition for writ of error coram nobis, claiming that he was entitled to a new trial on the basis of newly discovered evidence. The trial court denied the petition, and the Court of Criminal Appeals affirmed. At issue before the Supreme Court was whether a criminal defendant who pleads guilty may later seek to overturn his plea by way of a petition for writ of error coram nobis. The Supreme Court affirmed, holding (1) the Court’s holding in Wlodarz v. State that guilty pleas may be subject to a collateral attack via a petition for writ of error coram nobis is hereby overturned; and (2) the coram nobis statute is not available as a procedural mechanism for collaterally attacking a guilty plea.
Court Description:
Authoring Judge: Justice Jeffrey S. Bivins
Trial Court Judge: Judge John H. Gasaway, III
We granted permission to appeal in this case to determine whether a criminal defendant who pleads guilty may later seek to overturn his plea via a petition for writ of error coram nobis filed pursuant to Tennessee Code Annotated section 40-26-105. Although this Court held in Wlodarz v. State, 361 S.W.3d 490 (Tenn. 2012), that guilty pleas may be subject to a collateral attack via a petition for writ of error coram nobis, we now overturn that decision. We hold that the statute setting forth the remedy of error coram nobis in criminal matters does not encompass its application to guilty pleas. Accordingly, we affirm the judgment of the Court of Criminal Appeals on the separate grounds stated herein.
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