State of Tennessee v. George Ratliff

In 1998, the defendant, George E. Ratliff, was convicted of rape of a child, a Class A felony, for raping his six-year-old daughter and was sentenced to twenty-four years in the Department of Correction. He subsequently filed a direct appeal and a petition for writ of error coram nobis based on the victim's recantation of her testimony. The trial court summarily dismissed the petition as untimely, and the defendant appealed. The direct appeal and the error coram nobis appeal were consolidated, and this court reversed the trial court's dismissal of the petition, remanded the matter for a hearing, and stayed the direct appeal pending the trial court's ruling on the error coram nobis petition. See State v. Ratliff, 71 S.W.3d 291, 293 (Tenn. Crim. App. 2001), perm. to appeal denied (Tenn. 2002). On remand, the trial court denied the petition, and the defendant appeals. In his direct appeal, the defendant argues that the trial court erred in denying his motion for a new trial based upon newly discovered evidence, in denying his request for individual voir dire of two prospective jurors, and in ruling that the amount of time that lapsed between the victim's complaint and his arrest was irrelevant. Additionally, he argues that his sentence is excessive. Following our review, we affirm the defendant's conviction and sentence and affirm the trial court's denial of the petition for writ of error coram nobis.