Hall v. State, 558 S.W.3d 867

In Jan. 2012, Dra'Kease D. Hall pled guilty to first‑degree murder and attempted first‑degree murder and received an aggregate 600‑month prison sentence.
Hall filed a pro se petition for a writ of error coram nobis alleging two witnesses (Terrance Lang and Jasper Goodwin) were coerced by the prosecutor and an investigator into implicating him; affidavits from both witnesses recanted their prior statements and exonerated Hall.
On appeal Hall raised additional claims (Brady violation for an undisclosed plea offer to Lang; ineffective assistance for counsel's failure to interview the witnesses; and coercion of his guilty plea), but those new allegations were not presented to the trial court below.
The trial court denied coram nobis relief; the majority affirmed, holding the petition did not fit recognized coram nobis categories and the recantations were discoverable or otherwise insufficient.
A dissent argued the affidavits alleged prosecutorial and investigative coercion that would justify a hearing and potentially coram nobis relief to address a fundamental extrinsic fact.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether witness coercion/recantations justify coram nobis relief	Lang and Goodwin were coerced into implicating Hall; their affidavits recant and exonerate Hall	The allegations do not fit coram nobis categories; recantations are not cognizable and were discoverable before trial	Denied: recanted testimony alone does not warrant coram nobis; claims were groundless here
Whether Brady violation occurred (undisclosed plea offer to Lang)	Prosecutor failed to disclose a plea deal offered to Lang in exchange for testimony	New Brady allegation was not raised below and thus is not considered on appeal	Not addressed on the merits; appellate review limited to claims presented below
Whether guilty plea was involuntary/coerced due to counsel's failure to investigate witnesses	Hall says counsel failed to interview Lang/Goodwin, so plea was based on false belief about their testimony	Coram nobis is not the proper vehicle for attacking voluntariness of a plea; Rule 37.1 is the remedy; facts were discoverable pretrial	Denied: claim should have been raised under Rule 37.1 and facts were discoverable with due diligence
Whether the trial court abused its discretion by denying a hearing on the coram nobis petition	Hall: the attached affidavits alleged extrinsic, fundamental facts justifying a hearing	State: affidavits/claims were insufficient and groundless; no abuse of discretion	Majority: no abuse of discretion; dissent: circuit court should have held a hearing

Smith v. State, 2017 Ark. 236, 523 S.W.3d 354 (coram nobis standard and deference to trial‑court fact findings)
Nelson v. State, 2014 Ark. 91, 431 S.W.3d 852 (abuse‑of‑discretion and limits on coram nobis)
Brady v. Maryland, 373 U.S. 83 (Brady rule on prosecutor's duty to disclose favorable evidence)
Echols v. State, 354 Ark. 414, 125 S.W.3d 153 (coram nobis requires facts not discoverable with due diligence at trial)
Penn v. State, 282 Ark. 571, 670 S.W.2d 426 (function of coram nobis to fill procedural gaps for extrinsic facts)