Matthews v. State, 2016 Ark. 447

In 1981 Dennis Ray Matthews pled guilty to capital felony murder (underlying felony: aggravated robbery) and was sentenced to life without parole; judgment entered January 5, 1982.
On June 4, 2016, Matthews filed a pro se petition for writ of error coram nobis in Pulaski County circuit court claiming incompetence and coercion at the time of his plea.
Trial court denied the coram-nobis petition; Matthews appealed pro se to the Arkansas Supreme Court.
Matthews’s petition alleged mental incompetence awaiting evaluation and that he was coerced/threatened into pleading guilty; his filings below included a supporting affidavit alleging ineffective assistance of counsel.
The trial court found the claims were effectively claims of ineffective assistance and evidentiary assertions were conclusory and unsupported by facts; the Supreme Court reviewed whether the court abused its discretion.

Issue	Plaintiff's Argument (Matthews)	Defendant's Argument (State)	Held
Whether coram nobis may be used to raise ineffective-assistance claims	Matthews argued counsel was incompetent at plea and that this supports coram-nobis relief	State argued ineffective-assistance claims are not cognizable in coram-nobis and belong in a Rule 37.1 proceeding	Court held ineffective-assistance claims are not cognizable in coram-nobis and must be raised under Rule 37.1
Whether conclusory allegations of incompetence at plea meet coram-nobis factual-burden	Matthews claimed he was mentally incompetent and awaiting evaluation when he pled	State argued Matthews offered no factual specifics showing incompetence extrinsic to the record	Court held conclusory allegations without specific facts fail to meet coram-nobis burden
Whether allegations of coercion entitled petitioner to coram-nobis relief	Matthews alleged he was coerced/ threatened into pleading guilty	State argued no factual allegation of coercion (fear/duress/threats) sufficient to show compulsion	Court held allegations did not rise to recognized coercion and lacked factual support
Whether petitioner exercised due diligence in filing after long delay	Matthews filed 35 years after plea; argued merits of incompetence/coercion	State argued petitioner delayed and failed to show due diligence or excuse for delay	Court held Matthews failed to show due diligence; delay warranted denial

Larimore v. State, 17 S.W.3d 87 (Ark. 2000) (coram-nobis is an extraordinary remedy and functionally relieves judgment affected by unknown facts)
Newman v. State, 354 S.W.3d 61 (Ark. 2009) (describing coram-nobis burden and due-diligence requirement)
Tejeda-Acosta v. State, 427 S.W.3d 673 (Ark. 2013) (ineffective-assistance claims are not cognizable in coram-nobis)
Howard v. State, 403 S.W.3d 38 (Ark. 2012) (identifies traditional coram-nobis categories: insanity, coerced plea, prosecutorial suppression of material evidence, third-party confession)
Nelson v. State, 431 S.W.3d 852 (Ark. 2014) (standard of review and presumption of validity for coram-nobis proceedings)
White v. State, 460 S.W.3d 285 (Ark. 2015) (coram-nobis denial appropriate where claims are conclusory and untimely)