Noble v. State, 2015 Ark. 141

In 1992 Noble pled guilty to capital-felony murder to avoid the death penalty and was sentenced to life without parole; the circuit court entered judgment on October 26, 1992.
Noble filed a direct appeal; the Arkansas Supreme Court dismissed that appeal in 1993 because he failed to reserve the right to appeal under Ark. R. Crim. P. 24.3(b).
Over many years Noble pursued multiple collateral challenges; the record in CR-93-427 remained on file in the Arkansas Supreme Court and the Court has addressed several of his later petitions.
In August 2013 Noble filed a postconviction petition in Jefferson County and asked the circuit court to treat it as a petition for writ of error coram nobis; the circuit court dismissed for lack of jurisdiction because Noble had not shown this Court reinvested the trial court with jurisdiction.
Noble petitioned this Court to reinvest jurisdiction so the trial court could hear his coram-nobis claims that his 1992 guilty plea was coerced and that counsel was ineffective; the Court denied reinvestment, finding the claims are primarily ineffective-assistance claims not cognizable in coram-nobis and that the trial court lacked jurisdiction absent reinvestment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Noble must obtain this Court's leave to reinvest jurisdiction in the trial court before filing coram-nobis because the appellate record remains on file here	Noble contends this Court never acquired jurisdiction over his 1992 conditional plea appeal, so reinvestment is unnecessary	State argues the appellate record is on file here and, under controlling precedent, the trial court lacked jurisdiction until this Court reinvests it	Held: Because the record remained on file in this Court and Noble previously sought a direct appeal, Noble must seek reinvestment before the trial court can entertain coram-nobis relief
Whether Noble's allegations fall within coram-nobis categories (e.g., coerced plea) or are in substance Rule 37 ineffective-assistance claims	Noble frames claims as coercion of plea and a coerced/unknowing plea due to counsel's promises and failures	State contends the allegations are ineffective-assistance claims properly raised under Rule 37, not coram-nobis	Held: Most allegations are ineffective-assistance claims not cognizable in coram-nobis; no credible allegation that the plea was coerced or the product of duress to qualify for coram-nobis relief; petition to reinvest denied

Noble v. Norris, 368 Ark. 69, 243 S.W.3d 260 (affirming denial of habeas and rejecting argument plea entered on Sunday deprived circuit court of jurisdiction)
Noble v. State, 314 Ark. 240, 862 S.W.2d 234 (direct-appeal dismissal for failure to reserve right to appeal under Rule 24.3(b))
Dansby v. State, 343 Ark. 635, 37 S.W.3d 599 (coram-nobis generally filed in trial court when conviction entered on guilty plea unless record is on file in appellate court)
Tabor v. State, 326 Ark. 51, 930 S.W.2d 319 (strict compliance with Rule 24.3(b) required for appellate jurisdiction over conditional guilty pleas)
State v. Hudspeth, 191 Ark. 963, 88 S.W.2d 858 (coram-nobis addresses errors in the court that rendered the judgment)