Fred Ratliff, Jr. v. State of Tennessee

In February 2011, the Petitioner, Fred Ratliff, Jr., filed a petition for writ of error coram nobis, wherein he challenged his 1976 conviction for first degree murder. The Petitioner claimed that he had “compelling” new evidence of his innocence because the State failed to disclose a key prosecution witness’s juvenile record in violation of Brady v. Maryland, 373 U.S. 83 (1963). After an evidentiary hearing, the coram nobis court first dismissed the petition as time-barred, finding that due process did not require tolling of the one-year statute of limitations. Then, addressing the merits of the Petitioner’s Brady claim, the coram nobis court concluded that the Petitioner had not shown that the new evidence may have resulted in a different judgment had it been presented at trial. Following our review of the record, we affirm the judgment of the Scott County Circuit Court.