Jarrett v. State
2014 Ark. 272
Ark.2014Background
- In 1991, Jarrett was convicted of rape and first-degree battery and sentenced to life and 20 years, consecutively, which this court affirmed on appeal.
- Jarrett filed a pro se petition requesting reinvestment of jurisdiction in the trial court to consider a petition for writ of error coram nobis.
- A writ of error coram nobis is an extraordinarily rare remedy, available only under four specific categories and requiring extrinsic facts not known at judgment.
- Because the trial court can entertain coram nobis after an affirmance only with this court’s leave, the petition is properly filed in this court.
- Coram-nobis relief requires a showing of fundamental, extrinsic factual errors; the burden is on petitioner to demonstrate such errors before the judgment was rendered.
- The court denied the petition for reinvestment of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether coram-nobis relief may address withholding of material evidence. | Jarrett asserts that material evidence was withheld (Brady issue). | State contends no identifiable withheld exculpatory evidence is described. | Not shown due to lack of specifics; Brady claim fails. |
| Whether ineffective assistance of counsel at trial can be addressed via coram-nobis. | Jarrett claims ineffective trial counsel should be considered. | State argues such claims are outside coram-nobis scope and belong to Rule 37.1 proceedings. | Claim outside coram-nobis scope; petition denied on this ground. |
| Whether Martinez and Trevino require expanding coram-nobis to address ineffective assistance via Rule 37.1. | Jarrett relies on Martinez/Trevino to permit collateral challenge through coram nobis. | Martinez/Trevino do not expand coram-nobis to Rule 37.1 challenges. | Court declines to expand coram-nobis; not within its remit; petition denied. |
Key Cases Cited
- Peterson v. State, 336 Ark. 580, 986 S.W.2d 407 (1999) (Ark. 1999) (identifies categories of coram-nobis relief)
- Pitts v. State, 336 Ark. 580, 986 S.W.2d 407 (1999) (Ark. 1999) (recognizes four coram-nobis categories and burden of extrinsic facts)
- McFerrin v. State, 2012 Ark. 305 (Ark. 2012) (extrinsic-fact standard for coram-nobis)
- Cromeans v. State, 2013 Ark. 273 (Ark. 2013) (conditions for coram-nobis relief; rarity and scope)
- Charland v. State, 2013 Ark. 452 (Ark. 2013) (lists four coram-nobis categories)
- Howard v. State, 2012 Ark. 177 (Ark. 2012) (coram-nobis applicability and limits)
- Nelson v. State, 2014 Ark. 91 (Ark. 2014) (rejects expansion of coram-nobis to ineffective-assistance claims)
- Zulpo v. State, 2014 Ark. 14 (Ark. 2014) (limits scope of coram-nobis)
- Burton v. State, 2014 Ark. 44 (Ark. 2014) (requirement of court leave to proceed in trial court)
- Charland v. State, 2013 Ark. 452 (Ark. 2013) (per curiam decision on coram-nobis scope)