Patrick v. State, 2014 Ark. 15

Patrick, Jr. was convicted by jury in 2003 of rape and first-degree terroristic threatening; aggregate sentence 480 months.
The Arkansas Court of Appeals affirmed the conviction; no direct-court relief remained pending.
Patrick sought reinvestment of jurisdiction in the circuit court to pursue a writ of error coram nobis.
Coram-nobis relief is rare and available only for fundamental, extrinsic-errors in specific categories.
The court emphasized due diligence and that errors must be extrinsic to the record; issues challenging sufficiency or credibility generally aren’t cognizable in coram-nobis proceedings.
Petition denied for lack of due diligence and for failure to establish valid coram-nobis grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Anders briefing constitutes grounds for coram nobis	Patrick argues Anders brief taints appeal process	Anders brief is not a coram-nobis ground	Denied; not cognizable in coram-nobis.
Whether Brady/exculpatory-DNA/hair evidence supports coram-nobis relief	DNA/hair evidence was suppressed or improperly presented	Evidence was already known to defense; no suppression shown	Denied; not a Brady violation; claims relate to sufficiency rather than extrinsic errors.
Whether petition was timely/due diligence satisfied	Petition filed with reasonable diligence	Petitioner failed to show due diligence	Denied; due diligence not shown.

Pitts v. State, 336 Ark. 580, 986 S.W.2d 407 (1999) (Ark. 1999) (establishes coram-nobis scope and propriety per curiam)