Chestang v. State
2014 Ark. 477
| Ark. | 2014Background
- Chestang was convicted by jury in 2005 of aggravated robbery and sentenced to 240 months' imprisonment.
- The Arkansas Court of Appeals affirmed Chestang's conviction on direct appeal (unpublished, docket CACR 05-1170).
- Chestang filed a pro se petition in this court seeking reinvestment of jurisdiction in the trial court to consider a petition for writ of error coram nobis.
- A petition for leave to proceed in the trial court is required because coram nobis relief after direct appeal requires court permission (Hooper v. State, 2014 Ark. 16).
- Coram-nobis relief is rare and available only for certain fundamental-error categories (insanity at trial, coerced guilty plea, material evidence withheld, or a third-party confession) as described in Charland v. State.
- Petitioner claimed the prosecution withheld information from the probable-cause affidavit; the court applied Brady v. Maryland and Strickler v. Greene standards and found no Brady violation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the petition to reinvest jurisdiction is proper. | Chestang seeks coram-nobis relief by reinvesting jurisdiction to trial court. | State contends permission from this court is required and petition should be denied absent compelling grounds. | Petition denied; jurisdiction not reinvested. |
| Whether there was a Brady violation regarding the probable-cause affidavit. | Information in the affidavit was withheld from the defense and not disclosed to jurors. | Affidavit was available to defense; no withholding; disclosure issue insufficient. | No Brady violation established. |
| Whether claims about the probable-cause information are cognizable in coram-nobis proceedings. | Assertions about evidence viability undermine judgment. | Sufficiency and credibility issues are not cognizable in coram-nobis. | Issues concerning sufficiency of evidence are not cognizable in coram-nobis. |
Key Cases Cited
- Hooper v. State, 2014 Ark. 16 (Ark. 2014) (permission required to pursue coram nobis after direct appeal)
- Cromeans v. State, 2013 Ark. 273 (Ark. 2013) (coram-nobis rarity and stringent standards)
- McDaniels v. State, 2012 Ark. 465 (Ark. 2012) (coram-nobis available under compelling circumstances)
- Charland v. State, 2013 Ark. 452 (Ark. 2013) (one of four categories for coram-nobis relief)
- Pitts v. State, 336 Ark. 580, 986 S.W.2d 407 (Ark. 1999) (three components of Brady violation)
- Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (Brady standard: favorable evidence, suppression, prejudice)
- United States v. Bagley, 473 U.S. 667 (U.S. 1985) (defining materiality in Brady context)
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (duty to disclose exculpatory evidence)
- Wright v. State, 2014 Ark. 25 (Ark. 2014) (coram-nobis presumption of validity of conviction)
- Roberts v. State, 2013 Ark. 56 (Ark. 2013) (presumption of validity; coram-nobis context)
- Philyaw v. State, 2014 Ark. 130 (Ark. 2014) (cognizability limits of coram-nobis)