Timothy P. Guilfoy v. State of Tennessee

The Petitioner, Timothy P. Guilfoy, was convicted in 2011 of one count of rape of a child and three counts of aggravated sexual battery, and the trial court sentenced the Petitioner to forty years. In 2024, the Petitioner filed an untimely petition for writ of error coram nobis, his second, alleging newly discovered evidence of his actual innocence. The trial court dismissed the petition, finding that the newly discovered evidence did not provide clear and convincing proof of actual innocence, which is required to toll the one-year statute of limitations on such petitions. On appeal, the Petitioner contends the trial court erred when it denied his petition for relief because, in doing so, the court: (1) misapplied Clardy v. State, 691 S.W.3d 390 (Tenn. 2024); (2) failed to correctly analyze the new evidence and logically determine whether it established his actual innocence; (3) made improper credibility determinations and factual findings; (4) violated due process by dismissing the petition without considering preserved federal constitutional claims; and (5) failed to provide a meaningful state forum to adjudicate his preserved federal claims. After review, we affirm the trial court’s judgment.