Faulkens v. State
2017 Ark. 291
| Ark. | 2017Background
- Petitioner Brian Leonard Faulkens sought leave to reinvest jurisdiction in the trial court to pursue a writ of error coram nobis after his conviction was affirmed on appeal.
- Faulkens alleged four deficiencies: multiple amendments to the information, violations of the Interstate Agreement on Detainers, defects in arraignment procedures under Ark. Code Ann. § 16-701-706, and an illegal pretextual arrest.
- Coram nobis is an extraordinary post‑conviction remedy available only in narrow circumstances to address facts unknown at trial that would have prevented rendition of judgment.
- Arkansas recognizes four categories for coram nobis relief: insanity at trial, coerced guilty plea, material evidence withheld by prosecutor, and a third‑party confession occurring between conviction and appeal.
- The Court held that Faulkens’s claims challenged trial‑stage rulings or matters known at trial, and thus fell outside coram nobis scope; he did not show lack of jurisdiction or one of the recognized grounds for relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Multiple amendments to the information | Amendments violated Faulkens’s constitutional rights | State implicitly: procedural/merits issues not proper for coram nobis | Denied—challenges to trial proceedings are not coram nobis grounds |
| Interstate Agreement on Detainers violation | IAD (Ark. Code Ann. § 16-95-101) was violated | State: claim could have been raised at trial/appeal, not a coram nobis issue | Denied—claim known at trial, not within coram nobis scope |
| Arraignment procedure defects | Arraignment under Ark. Code Ann. § 16-701-706 was defective | State: procedural/arising at trial, reviewable on direct appeal, not coram nobis | Denied—procedural trial errors are outside coram nobis relief |
| Illegal pretextual arrest | Arrest was illegal and tainted proceedings | State: arrest issue is a trial/record matter, not a coram nobis basis | Denied—does not show jurisdictional defect or recognized coram nobis category |
Key Cases Cited
- Newman v. State, 354 S.W.3d 61 (2009) (trial court may entertain coram nobis after appellate affirmance only with permission)
- Howard v. State, 403 S.W.3d 38 (2012) (enumerating four categories for coram nobis relief)
- Roberts v. State, 425 S.W.3d 771 (2013) (coram nobis is an extraordinary writ for fundamental errors)
- Green v. State, 502 S.W.3d 524 (2016) (coram nobis does not provide avenue to challenge trial‑stage rulings known at trial)
- Jackson v. State, 520 S.W.3d 242 (2017) (burden is on petitioner to demonstrate a basis for coram nobis)