Anderson v. State
2012 Ark. 270
| Ark. | 2012Background
- Petitioner David Alan Anderson sought writ of error coram nobis after direct appeal affirmed and petitioned to reinvest jurisdiction in the trial court.
- The court granted Anderson's motion to amend the petition, denied several motions to compel and dismiss, and denied the petition with amendments.
- The issues focused on alleged trial court comments, prosecutorial comments, and the validity of the mental evaluation and insanity claims.
- The court recognized coram-nobis relief is extraordinary and available only for hidden, extrinsic facts not known at trial.
- Anderson claimed insanity at the time of trial and other trial-errors; most claims were found not cognizable or lacked due diligence.
- The court ultimately denied the petition and related amendments, granting one motion to add a claim but denying others.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is coram-nobis relief warranted here? | Anderson argues there are hidden, extrinsic facts warranting relief | State contends the claims are not cognizable or lack hidden facts | No; claims not meritorious or not hidden facts; writ denied |
| Are due-diligence requirements satisfied to grant relief? | Anderson asserts diligence in discovering facts | State argues failure to show due diligence | No; due diligence not shown for most claims |
| Do recanted testimony and prosecutorial comments support coram-nobis relief? | Recantations and misconduct claims were raised | Recantations and comments do not establish hidden facts or cognizable grounds | Not cognizable; relief denied |
Key Cases Cited
- Martin v. State, 2012 Ark. 44 (2012) (writ available only for meritorious, hidden facts)
- Hogue v. State, 2011 Ark. 496 (2011) (extremely narrow remedy, extraordinary relief)
- Webb v. State, 2009 Ark. 550 (2009) (insanity at time of trial recognized as a coram-nobis category)
- Flanagan v. State, 2010 Ark. 140 (2010) (due diligence required; delay analyzed per curiam rule)
- Cooper v. State, 2010 Ark. 471 (2010) (issue known at trial not cognizable in coram-nobis)
- Scott v. State, 2010 Ark. 363 (2010) (issues known at trial not cognizable; due diligence required)