Noble v. State
2014 Ark. 332
Ark.2014Background
- Leonard Noble was convicted in 1999 of residential burglary and rape; sentenced as a habitual offender to 900 months; conviction affirmed on direct appeal.
- Noble filed a pro se petition asking the Arkansas Supreme Court to reinvest jurisdiction in the trial court so he could pursue a writ of error coram nobis.
- Noble alleges the State suppressed exculpatory evidence (hospital/rape‑kit records, lack of DNA/match, victim inability to identify) that would show actual innocence, invoking Brady.
- The Court explains coram-nobis is an extraordinary remedy limited to fundamental errors (e.g., insanity at trial, coerced plea, withheld material evidence, third‑party confession) and requires facts extrinsic to the record.
- The Court finds Noble’s allegations are vague: he fails to identify specific suppressed evidence or show a reasonable probability the outcome would have been different.
- The petition was denied for failing to meet the burden required for a coram-nobis/Brady claim; sufficiency‑of‑evidence complaints are not cognizable in coram-nobis proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court should reinvest jurisdiction to permit a coram‑nobis petition | Noble: State suppressed favorable evidence (hospital/rape kit, medical findings, DNA) showing actual innocence | State: No specific suppressed evidence identified; defense knew of hospital exam; no showing of prejudice or undisclosed material | Denied — jurisdiction not reinvested; allegations too vague to establish Brady or coram‑nobis relief |
| Whether alleged suppression satisfies Brady elements | Noble: Withheld evidence was favorable and suppressed | State: No proof specific favorable evidence was withheld or that disclosure would likely change result | Denied — petitioner failed to show specific suppressed evidence or reasonable probability of different outcome |
| Whether sufficiency‑of‑evidence claims are reviewable in coram‑nobis | Noble: Argues lack of medical/DNA evidence undermines conviction | State: Sufficiency issues belong on direct appeal or trial record | Denied — sufficiency claims not cognizable in coram‑nobis proceedings |
| Whether petitioner met burden to show extrinsic fundamental error | Noble: Asserts diligence in obtaining withheld evidence and actual innocence | State: Strong presumption of validity of conviction; petitioner must show extrinsic fact preventing rendition of judgment | Denied — petitioner did not meet burden to demonstrate extrinsic, fundamental error |
Key Cases Cited
- Pitts v. State, 336 Ark. 580, 986 S.W.2d 407 (1999) (Brady suppression can justify coram‑nobis relief)
- Troglin v. State, 257 Ark. 644, 519 S.W.2d 740 (1975) (strong presumption of validity of convictions in coram‑nobis context)
- Penn v. State, 282 Ark. 571, 670 S.W.2d 426 (1984) (burden on petitioner to show extrinsic facts warranting coram‑nobis)
- Strickler v. Greene, 527 U.S. 263 (1999) (three‑part Brady test and reasonable‑probability standard)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose exculpatory evidence)
- United States v. Bagley, 473 U.S. 667 (1985) (reasonable‑probability standard for suppressed impeachment evidence)