Jefferson v. State, 2017 Ark. 293

Wesley Jefferson was convicted by a jury of capital murder and other felonies; this court affirmed the convictions in Jefferson v. State (2008).
Jefferson sought permission to reinvest jurisdiction in the trial court to file a writ of error coram nobis because the trial court cannot entertain such a petition after an affirmed appeal without this Court's leave.
He alleged the State violated Brady by failing to disclose a legislative commentary to the capital-murder statute that he says would have supported a defense that his conduct did not meet the statutory elements of capital murder.
He also alleged the trial evidence was insufficient to sustain the capital-murder conviction.
The Court reviewed the standards for coram nobis (extraordinary, limited categories, requires a factual error extrinsic to the record) and for Brady claims (favorable evidence, suppression by the State, and prejudice).
The Court denied the petition, concluding (1) insufficiency claims are not cognizable in coram nobis and (2) a statutory commentary is not Brady material because Brady does not obligate the State to perform legal research or disclose published legal materials.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether coram nobis relief should be allowed to consider a Brady claim based on withheld legislative commentary	Jefferson: State withheld legislative commentary that was material and favorable; its nondisclosure violated Brady	State: Published statutory commentary is available public law; Brady does not require prosecutors to perform or disclose legal research	Denied — commentary not Brady material; State had no duty to research and disclose published legal materials
Whether coram nobis may be used to challenge sufficiency of the evidence	Jefferson: Evidence was insufficient to sustain capital murder conviction	State: Sufficiency challenges are direct appeals, not coram nobis grounds	Denied — sufficiency challenge is not cognizable in coram nobis

Jefferson v. State, 372 Ark. 307, 276 S.W.3d 214 (Ark. 2008) (prior appeal affirming convictions)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecutor must disclose materially favorable evidence)
Strickler v. Greene, 527 U.S. 263 (1999) (three-element Brady standard and reasonable-probability test)
United States v. Bagley, 473 U.S. 667 (1985) (materiality standard for undisclosed evidence)
Roberts v. State, 2013 Ark. 56, 425 S.W.3d 771 (Ark. 2013) (burden to show extrinsic factual error for coram nobis)
Howard v. State, 2012 Ark. 177, 403 S.W.3d 38 (Ark. 2012) (enumeration of coram nobis categories)
Isom v. State, 2015 Ark. 225, 462 S.W.3d 662 (Ark. 2015) (Brady requires State to have wrongfully withheld material evidence)
State v. Larimore, 341 Ark. 397, 17 S.W.3d 87 (Ark. 2000) (coram nobis is an extraordinary remedy with strong presumption of validity of conviction)
Scott v. State, 2017 Ark. 199, 520 S.W.3d 262 (Ark. 2017) (sufficiency claims are direct challenges not appropriate for coram nobis)