Jones v. State, 2017 Ark. 334

Milton Jasper Jones was convicted of capital felony murder for the killing of Annie Bell Hall Killingsworth and sentenced to life without parole; conviction was affirmed on appeal.
After conviction, Jones filed pro se second and supplemental petitions asking this court to reinvest jurisdiction in the trial court to pursue a writ of error coram nobis.
Jones alleges the State withheld a codefendant Roosevelt Ferguson’s confession to burglarizing the victim’s apartment, and that Ferguson had implicated Jones and Erma McCoy in the murder.
At trial: Jones’s fingerprints were found in the victim’s home; Jones confessed to participating in the burglary and murder (later claiming the confession was coerced); Jones testified at trial denying participation in the burglary or murder and saying his confession was coerced.
Jones argues that disclosure of Ferguson’s confession would have allowed different defensive strategies (including blaming Ferguson) and that nondisclosure violated Brady v. Maryland.
The court considered whether Jones’s allegations met the narrow coram-nobis standards and whether the alleged withheld evidence was material and prejudicial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court should reinvest jurisdiction to permit a coram-nobis petition alleging Brady violation for withheld Ferguson confession	Jones: State suppressed Ferguson’s confession to burglary which was favorable/impeaching and would have changed defense strategy	State: Allegations do not show material, prejudicial suppression that would have prevented rendition of judgment	Denied — petition fails to allege facts establishing materiality/prejudice required for Brady-based coram-nobis relief
Whether alleged confession fits fourth category of coram-nobis (post-conviction third-party confession)	Jones: Ferguson’s statement implicating others supports coram-nobis relief under third- or fourth-category errors	State/Court: Fourth category is limited to confessions occurring between conviction and appeal; this confession allegedly occurred before arrest	Denied — confession occurred before arrest so fourth-category relief inapplicable; claim treated as Brady (third category) and fails on materiality

Brady v. Maryland, 373 U.S. 83 (1963) (prosecution’s suppression of favorable evidence violates due process)
Noble v. State, 2015 Ark. 141 (2015) (identifies categories of coram-nobis relief)
Green v. State, 2016 Ark. 386 (2016) (coram-nobis is narrow; withheld evidence must be material and prejudicial)
Clark v. State, 358 Ark. 469 (2004) (writ available for facts hidden or unknown at trial)
Penn v. State, 282 Ark. 571 (1984) (fourth-category coram-nobis limited to confessions occurring between conviction and appeal)