Goff v. State, 398 S.W.3d 896

Goff was convicted of first-degree murder in 1996 and sentenced to life imprisonment.
On direct appeal, guilt was affirmed but sentencing error led this court to remand for resentencing, which again resulted in a life sentence.
Goff now seeks to reinvest jurisdiction in the trial court to consider a writ of error coram nobis and mentions a habeas corpus claim.
A writ of error coram nobis is available only in rare cases and requires showing of fundamental error extrinsic to the record that would have prevented judgment had it been known.
Petitioner contends that three discovered documents (Brad Y. Price dispatcher report, Jim Resterholz report, and a police radio log) were withheld and would show another person committed the crime.
The court evaluates whether the withheld materials meet Brady requirements and would have prevented rendition of the judgment; it also addresses the habeas claim and jurisdictional considerations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether coram nobis relief is warranted for Brady material.	Goff argues the three documents were Brady Brady-material and withheld.	State contends suppression must show the documents would have prevented judgment and changed the outcome.	Denied; no reasonable probability the outcome would have differed.
Whether the three documents would have impacted the guilt finding.	Documents show third-party involvement and door not blocked by victim's body.	Evidence still overwhelmingly supported petitioner as the killer; other testimony undermines claim of third-party involvement.	Not enough to undermine guilt; cumulative effect insufficient to warrant relief.
Whether petitioner is entitled to habeas corpus relief.	Requests habeas relief based on asserted jurisdictional or facial invalidity grounds.	Habeas relief requires facial invalidity or lack of jurisdiction, which petitioner does not establish.	Denied; no facial invalidity or lack of jurisdiction shown.

Pitts v. State, 336 Ark. 580, 986 S.W.2d 407 (Ark. 1999) (per curiam; four categories of fundamental errors)
Sanders v. State, 374 Ark. 70, 285 S.W.3d 630 (Ark. 2008) ( Brady material analysis; burden on petitioner)
Newman v. State, 2009 Ark. 539, 354 S.W.3d 61 (Ark. 2009) (coram nobis framework and extrinsic-fact inquiry)
Grant v. State, 2010 Ark. 286, 365 S.W.3d 894 (Ark. 2010) (per curiam; use of coram nobis in exceptional cases)
Pinder v. State, 2011 Ark. 401, 2011 WL 4492362 (Ark. 2011) (per curiam; Brady claim relevance to coram nobis relief)