Harris v. State
2014 Ark. 83
Ark.2014Background
- Appellant Ed Deshawn Harris pleaded guilty to first-degree murder in 2009 and was sentenced to 480 months in prison.
- In 2013 Harris filed a pro se petition for writ of error coram nobis asserting coerced plea due to ineffective assistance of counsel and incompetence at the time of the plea.
- Circuit court denied relief, and Harris timely appealed the denial.
- Harris sought an extension of time to file his brief-in-chief on appeal.
- The Arkansas Supreme Court dismissed the appeal as moot, holding the appeal could not prevail on the merits.
- The court explained coram-nobis relief is rare and limited to four categories, and counsel-ineffectiveness claims belong in postconviction Rule 37.1 proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the appeal from the postconviction denial may proceed | Harris contends the appeal should be reviewed on the merits. | State argues the appeal must be dismissed as moot because relief could not be obtained. | Appeal dismissed; moot. |
| Whether writ of error coram nobis is available for ineffective-assistance grounds | Harris asserts coram-nobis relief for coerced plea due to counsel issues. | State contends ineffective assistance is not within coram-nobis scope and should be raised under Rule 37.1. | Coram-nobis relief limited; not available for ineffective assistance grounds. |
| Whether Harris was competent at the time of plea | Harris claims significant cognitive impairment from drug use rendered plea involuntary. | State disputes hidden competency issue; no factual basis shown to support hidden defect. | Competency issue not proven; not a ground for coram-nobis relief. |
Key Cases Cited
- Demeyer v. State, 2013 Ark. 456 (Ark. 2013) (appeal from postconviction denial not permitted if no likelihood of success)
- Morgan v. State, 2013 Ark. 341 (Ark. 2013) (per curiam; mootness governs appealability)
- Cromeans v. State, 2013 Ark. 273 (Ark. 2013) (coram-nobis rarity; relief only in extraordinary cases)
- Greene v. State, 2013 Ark. 251 (Ark. 2013) (coram-nobis addresses certain limited categories)
- Burks v. State, 2013 Ark. 188 (Ark. 2013) (burden on petitioner; judgments presumed valid)
- Lee v. State, 2012 Ark. 401 (Ark. 2012) (review of writ denial; abuse of discretion standard)
- Watts v. State, 2013 Ark. 485 (Ark. 2013) (ineffectiveness claims not proper coram-nobis grounds)
- Hall v. State, 2013 Ark. 404 (Ark. 2013) (ineffectiveness claims must be raised under Rule 37.1)
- State v. Tejeda-Acosta, 2013 Ark. 217 (Ark. 2013) (coram-nobis is not a substitute for Rule 37.1)