Gray v. State, 540 S.W.3d 658

James Gray pleaded guilty in April 2016 to first-degree murder and aggravated robbery and received a sentence totaling 564 months.
On April 10, 2017, Gray filed a pro se petition for a writ of error coram nobis, alleging his plea was not voluntary or intelligent due to incompetent counsel.
Gray's specific claims: he did not validly waive the right to competent counsel; counsel negotiated the plea ineffectively; counsel misadvised him that he would serve 70% of his sentence instead of 100%; and he pleaded guilty under coercion from threats of a life sentence.
The trial court denied coram nobis relief; Gray appealed and moved for an extension of time to file his appellate brief (he tendered only one copy due to prison copier problems).
The majority dismissed the appeal as barred because Gray's claims were not cognizable in coram nobis proceedings and thus he could not prevail; it also deemed the extension motion moot.
Justice Hart dissented, arguing the court lacked jurisdiction to decide the appeal because Gray had not perfected it and that dismissing the appeal denied him due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ineffective-assistance-of-counsel claims are cognizable in coram nobis	Gray: counsel was ineffective at plea, so coram nobis should remedy the invalid plea	State: ineffective-assistance claims must be raised under Rule 37.1, not coram nobis	Not cognizable in coram nobis; appeal dismissed
Whether plea was coerced by threat of a harsher sentence	Gray: he pleaded guilty because of threats of a life sentence	State: mere fear of a harsher sentence is not coercion	Mere pressure from fear of a harsher sentence is not coercion; claim fails
Whether the appellate court could decide the appeal while Gray's brief filing was incomplete	Gray (dissent): he submitted one copy and sought more time due to prison copier problems; court should have waived copy requirement or granted extension	Majority: reviewed the record and concluded appeal could not succeed; extension motion is moot	Majority proceeded to dismiss on merits; dissent contends the court lacked jurisdiction and denied due process

Brown v. State, 522 S.W.3d 791 (Ark. 2017) (appeals may be dismissed when it is clear the appellant cannot prevail)
Nelson v. State, 431 S.W.3d 852 (Ark. 2014) (describing coram nobis scope and four categories of cognizable errors)
State v. Tejeda-Acosta, 427 S.W.3d 673 (Ark. 2013) (coram nobis is not a substitute for Rule 37.1 ineffective-assistance claims)
Baptist Health Sys. v. Rutledge, 488 S.W.3d 507 (Ark. 2016) (dismissal of declaratory-judgment appeals for lack of justiciable issue)