Johnson v. State, 2016 Ark. 329

Ronnie Johnson pleaded guilty on December 14, 2015 to two counts of robbery and received an aggregate 480-month sentence.
On January 14, 2016 Johnson filed a pro se coram nobis petition, a petition alleging an illegal sentence, a motion for an evidentiary hearing, and a notice alleging fraud, claiming counsel induced him to plead guilty and failed to obtain E-Z Mart video surveillance.
He argued counsel’s alleged ineffectiveness and an asserted inducement/coercion (“take this deal or else”) rendered his plea involuntary and his sentence illegal.
The trial court denied relief, finding Johnson failed to show coercion, presented no proof, was not entitled to an evidentiary hearing, and that his sentence was not illegal.
Johnson appealed and moved for a transcribed record and extension of time to file a brief; the Supreme Court dismissed the appeal as having no merit and declared the motion moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether coram nobis relief is available for counsel’s failure to obtain surveillance evidence	Johnson: counsel’s failure to obtain E‑Z Mart video prejudiced him and induced a guilty plea	State: claim is ineffective-assistance-of-counsel, not a coram-nobis ground	Denied — ineffective-assistance claims are not cognizable in coram-nobis proceedings
Whether plea was coerced such that coram nobis relief is warranted	Johnson: counsel told him to “take this deal or else,” inducing his plea	State: no allegations of fear, duress, threats, or other coercion; no supporting facts	Denied — allegations do not rise to coercion required for coram-nobis relief
Whether the sentence is illegal on its face due to alleged inducement or counsel error	Johnson: plea inducement and counsel error render sentence illegal	State: claims are non-jurisdictional and should have been raised under Rule 37.1; no facial illegality shown	Denied — sentence not shown to be jurisdictionally illegal; remedy is Rule 37.1 when appropriate
Procedural: whether appeal should proceed and whether motion for transcript/extension should be granted	Johnson sought transcribed record and extension to file brief	State: appeal lacks merit; transcript/extension unnecessary if appeal dismissed	Appeal dismissed as frivolous/without merit; motion moot

Nelson v. State, 431 S.W.3d 852 (Ark. 2014) (abuse-of-discretion standard and coram-nobis claims groundless)
State v. Larimore, 17 S.W.3d 87 (Ark. 2000) (coram-nobis is an extraordinary remedy; conviction presumed valid)
Roberts v. State, 425 S.W.3d 771 (Ark. 2013) (petitioner bears burden to show fundamental factual error extrinsic to record)
Howard v. State, 403 S.W.3d 38 (Ark. 2012) (enumeration of four categories for coram-nobis relief)
White v. State, 460 S.W.3d 285 (Ark. 2015) (ineffective-assistance claims not cognizable in coram-nobis)
Noble v. State, 460 S.W.3d 774 (Ark. 2015) (examples of coercion cognizable for coram-nobis)
Williams v. State, 479 S.W.3d 544 (Ark. 2016) (claims of facially illegal sentence remain reviewable but non-jurisdictional claims must follow Rule 37 procedures)
Halfacre v. State, 460 S.W.3d 282 (Ark. 2015) (section allowing challenge to facially illegal sentence remains in effect)