New Hampshire v. Santamaria

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Defendant Paul Santamaria appealed a superior court order dismissing his petition for a writ of coram nobis. In 1998, defendant was convicted of first degree assault. His trial counsel filed a motion to set aside the verdict, which the court denied. Subsequently, the court sentenced the defendant to incarceration for twelve months. Defendant’s trial counsel withdrew from the case and, through appellate counsel, defendant appealed to the New Hampshire Supreme Court to challenge the sufficiency of the evidence at trial and the trial court’s decision to permit a police officer to testify as an expert witness. At that time, the Court affirmed his conviction. On December 30, 2014, defendant filed a petition for a writ of coram nobis seeking to have his conviction vacated for ineffective assistance of trial counsel. The trial court denied defendant’s petition, ruling that he was procedurally barred because he "could have, and should have, raised this claim earlier either on direct appeal, in a motion for a new trial, or in a habeas corpus petition," and because he failed to show "sound reasons" for failing to seek proper relief earlier. A common threshold requirement to bringing a petition for a writ of coram nobis is that "sound reasons exist[] for fail[ing] to seek appropriate earlier relief." Here, the Supreme Court found defendant failed to meet that requirement. Defendant argued he could not have brought his ineffective assistance claim earlier in a direct appeal, a motion for a new trial, or a petition for a writ of habeas corpus. "Even if we assume without deciding that the defendant’s claim could not have been brought in a direct appeal, we conclude that he could have brought his claim in a motion for a new trial or a petition for a writ of habeas corpus." View "New Hampshire v. Santamaria" on Justia Law