Noble v. State
2015 Ark. 215
| Ark. | 2015Background
- Leonard Noble was convicted by jury in 1999 of residential burglary and rape and sentenced as a habitual offender to an aggregate 900-month term; the Arkansas Court of Appeals affirmed.
- Noble filed a pro se request (2014) asking the Arkansas Supreme Court to reinvest jurisdiction in the trial court so he could pursue a writ of error coram nobis; a prior coram-nobis request was denied earlier in 2014.
- Coram-nobis is an extraordinary postconviction remedy available only with this Court's permission and only for fundamental factual errors extrinsic to the record (limited to insanity at trial, coerced plea, withheld material evidence, or postconviction third-party confession).
- Noble’s second petition alleged: longstanding mental illness/insanity at time of trial, the trial court should have ordered psychological evaluation and allowed a defense expert, the prosecution withheld exculpatory evidence (hair Q-11 and medical report), and trial counsel was ineffective for failing to ask certain questions.
- The Court evaluated whether Noble presented factual, previously unknown, and material evidence fitting coram-nobis categories and whether any Brady suppression occurred; it found his submissions insufficient and denied the petition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Insanity at time of trial | Noble: longstanding mental problems and affidavit evidence show incompetence/insanity at trial | State: petitioner failed to show new factual evidence unknown at trial proving incompetence | Court: dismissed — affidavit and general assertions insufficient to overcome presumption of validity; no new facts shown |
| Trial-court procedure (psych eval / expert) | Noble: trial court erred by not ordering psychological evaluation and not allowing defense expert to test evidence | State: procedural/trial errors are not cognizable in coram-nobis; issues go to trial/appeal record | Court: denied — these are trial errors, not proper coram-nobis grounds |
| Brady (withheld exculpatory evidence) | Noble: State withheld hair evidence (Q-11) and medical report that would have exculpated him | State: evidence about hairs and medical report was known/mentioned at trial; petitioner hasn’t shown suppression | Court: denied — petitioner failed to show evidence was suppressed or that nondisclosure was material under Brady/Strickler |
| Ineffective assistance of counsel | Noble: trial counsel should have asked certain questions; counsel was ineffective | State: IAC claims belong in a Rule 37.1 postconviction petition, not coram-nobis | Court: denied — coram-nobis is not a substitute for Rule 37.1 IAC claims |
Key Cases Cited
- Slocum v. State, 2014 Ark. 398, 442 S.W.3d 858 (trial court may consider coram-nobis only after this Court grants permission)
- Dansby v. State, 343 Ark. 635, 37 S.W.3d 599 (per curiam) (procedures for coram-nobis jurisdiction)
- Cromeans v. State, 2013 Ark. 273 (coram-nobis is an extraordinary remedy; strong presumption of validity)
- Greene v. State, 2013 Ark. 251 (describing coram-nobis function and limited categories)
- Burks v. State, 2013 Ark. 188 (burden on petitioner to show fundamental fact extrinsic to record)
- Millsap v. State, 2014 Ark. 493, 449 S.W.3d 701 (coram-nobis petition must fully disclose specific facts relied upon)
- Brady v. Maryland, 373 U.S. 83 (suppression of favorable evidence violates due process)
- Strickler v. Greene, 527 U.S. 263 (materiality standard for Brady: reasonable probability of a different result)
- Hooper v. State, 2015 Ark. 108 (Brady and coram-nobis principles reaffirmed; IAC not cognizable in coram-nobis)