Noble v. State, 2016 Ark. 463

Leonard Noble was convicted by a jury in 1999 of residential burglary and rape and sentenced as a habitual offender to 900 months; the Arkansas Court of Appeals affirmed.
In August 2016 Noble filed his third pro se petition asking the Arkansas Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis.
Noble alleges the State withheld medical reports, rape-kit and DNA/hair test results (including an item labeled “Q-11”), that no witnesses identified him, and that a subpoenaed witness named Linda was not called because the prosecutor told defense counsel not to.
Coram-nobis relief addresses only fundamental, extrinsic errors of fact unknown at trial (categories include insanity at trial, coerced plea, suppressed material evidence, or third‑party confession).
The court had denied Noble’s two prior coram-nobis petitions (2014 and 2015), finding his claims either known at trial, sufficiency challenges, or ineffective-assistance claims — all generally outside coram-nobis relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Noble alleged newly discovered, extrinsic facts warranting coram-nobis relief	Noble: State suppressed exculpatory medical/rape‑kit/DNA/hair results that would have prevented conviction	State: Alleged evidence was known or could have been known at trial; claims attack sufficiency or are otherwise cognizable in other proceedings	Denied — claims are vague, largely known at trial, not within coram‑nobis scope
Whether Noble shown insanity at time of trial	Noble: asserts longstanding mental problems (affidavit)	State: bare assertions and affidavit insufficient to establish incompetence at trial	Denied — inadequate to meet coram‑nobis standard for insanity claims
Whether failure to call witness (Linda) shows Brady or prosecutor misconduct	Noble: prosecutor told defense not to call Linda; her testimony would have been exculpatory	State: allegation is conclusory; no specific suppressed material shown	Denied — conclusory, insufficient to establish suppression or prejudice
Whether repeated petitions should be entertained	Noble: renews arguments and adds some variations	State: court need not reopen repeatedly; issues could have been raised earlier or in other proceedings	Denied — court exercises discretion; due process does not require unlimited petitions

Newman v. State, 354 S.W.3d 61 (describing function and burden for coram-nobis)
Howard v. State, 403 S.W.3d 38 (listing four categories for coram-nobis relief)
State v. Larimore, 17 S.W.3d 87 (coram-nobis is an extraordinarily rare remedy)
Noble v. State, 462 S.W.3d 341 (prior denial; insufficiency and scope of coram-nobis)
Noble v. State, 439 S.W.3d 47 (prior denial; withheld-evidence and sufficiency claims known at trial)
Brady v. Maryland, 373 U.S. 83 (establishing elements for suppression-of-evidence claims)