Franklin v. State, 476 S.W.3d 786

Frank Franklin was convicted of rape in 1991, sentenced as a habitual offender to 300 years, and this Court affirmed on direct appeal.
Franklin later filed a pro se Rule 37.1 postconviction petition, which the trial court denied as untimely; his appeal was dismissed for failure to file a brief.
Franklin now sought leave to reinvest jurisdiction in the trial court to consider a writ of error coram nobis, asserting he was denied a speedy trial.
Permission from this Court is required before a trial court may entertain a coram-nobis petition after an affirmed judgment.
The coram-nobis remedy is extraordinary, presumes the conviction valid, and is limited to fundamental factual errors extrinsic to the record in four narrow categories.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether coram-nobis relief is available for an asserted speedy-trial violation	Franklin argued his constitutional speedy-trial right was violated and sought coram-nobis relief	State argued coram-nobis is limited to four categories of extrinsic fundamental error and does not encompass ordinary trial error	Denied — a speedy-trial claim is trial error not cognizable in coram-nobis and thus does not state a ground for the writ

Franklin v. State, 308 Ark. 539, 825 S.W.2d 263 (affirming conviction)
Newman v. State, 2009 Ark. 539, 354 S.W.3d 61 (permission required to file coram-nobis after affirmed judgment; explains writ function)
State v. Larimore, 341 Ark. 397, 17 S.W.3d 87 (coram-nobis is extraordinary)
Westerman v. State, 2015 Ark. 69, 456 S.W.3d 374 (strong presumption of validity attends coram-nobis)
Roberts v. State, 2013 Ark. 56, 425 S.W.3d 771 (burden to show fundamental fact extrinsic to record)
Howard v. State, 2012 Ark. 177, 403 S.W.3d 38 (lists four categories cognizable in coram-nobis)
State v. Wilmoth, 369 Ark. 346, 255 S.W.3d 419 (speedy-trial allegation not sufficient to void judgment)
Rodgers v. State, 2013 Ark. 294 (speedy-trial claims are trial error, not coram-nobis)