McClinton v. State, 2015 Ark. 161

Petitioner Edmond McClinton was convicted of rape in Jefferson County Circuit Court in 2014 and sentenced to life; his direct appeal is pending before the Arkansas Supreme Court.
After the trial transcript was filed in this court, the trial court lost jurisdiction, so McClinton sought this court’s permission to reinvest jurisdiction to permit a coram nobis petition in the trial court.
McClinton filed a pro se petition arguing multiple defects: the trial court fixed punishment, failure to rule on defense motions, denial of several preliminary procedural protections (prompt first appearance, arrest warrant, preliminary hearing, grand jury, arraignment), lack of corpus delicti/probable cause, and other violations of Arkansas law and fairness.
The Arkansas Supreme Court reviews requests to reinvest jurisdiction only when the proposed coram nobis attack appears meritorious and raises reasonable, probable allegations of error.
Coram nobis is an extraordinary remedy available only for fundamental errors of fact extrinsic to the record (e.g., insanity at trial, coerced plea, material Brady evidence, third-party confession) that could not have been raised earlier.
The court found McClinton’s claimed grounds were apparent from the record and could have been raised at trial, so they do not satisfy the extrinsic-fact requirement for coram nobis; the petition to reinvest jurisdiction was denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether this court should reinvest jurisdiction to allow a coram nobis petition	McClinton: reinvest so trial court can consider coram nobis claims of multiple trial and jurisdictional defects	State: petition must show meritorious, extrinsic factual errors not discoverable at trial	Denied — petitioner failed to show coram nobis grounds meritorious or extrinsic to the record
Whether alleged defects (court-fixed punishment; unresolved motions) warrant coram nobis	McClinton: sentencing and unruled motions deprived him of proper process/fairness	State: such defects were or could have been raised at trial/appeal; not extrinsic errors	Denied — these claims were apparent from the record and not proper coram nobis grounds
Whether denial of preliminary procedures (first appearance, warrant, preliminary hearing, grand jury, arraignment) supports coram nobis	McClinton: procedural deprivation undermined conviction	State: procedural complaints are reviewable on direct appeal; not new extrinsic facts	Denied — could have been raised earlier; not meeting coram nobis standard
Whether lack of corpus delicti or probable cause qualifies for coram nobis relief	McClinton: corpus delicti/probable-cause not established, requiring relief	State: those are record-based issues that could be pursued on direct appeal	Denied — factual basis is not extrinsic; coram nobis inappropriate

Echols v. State, 354 Ark. 414, 125 S.W.3d 153 (Ark. 2003) (standard for granting reinvestment and evaluating coram nobis allegations)
Howard v. State, 2012 Ark. 177, 403 S.W.3d 38 (Ark. 2012) (coram nobis is an extraordinary, rarely granted remedy)
Pitts v. State, 336 Ark. 580, 986 S.W.2d 407 (Ark. 1999) (enumeration of categories for coram nobis relief)
Roberts v. State, 2013 Ark. 56, 425 S.W.3d 771 (Ark. 2013) (presumption of validity attends convictions in coram nobis proceedings)
Penn v. State, 282 Ark. 571, 670 S.W.2d 426 (Ark. 1984) (coram nobis principles and strong presumption of validity)
Troglin v. State, 257 Ark. 644, 519 S.W.2d 740 (Ark. 1975) (historic treatment of coram nobis and conviction validity)