Scott v. State, 2014 Ark. 199

In 2006 Broderick Don Scott pled guilty to six felonies and, as a habitual offender, received an aggregate 360-month sentence.
In 2013 Scott filed a pro se petition for writ of error coram nobis challenging the 2006 judgment; the trial court denied the petition on November 26, 2013.
Scott did not file a notice of appeal within the 30-day appellate window; he filed it 85 days after the order and then sought leave to proceed with a belated appeal to the Arkansas Supreme Court.
Scott’s sole justification was that the circuit clerk failed to promptly notify him of the entry of the order denying coram nobis relief.
The circuit court record and Arkansas law were analyzed to determine whether Scott showed "good cause" for missing the appeal deadline.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Scott may proceed with a belated appeal from denial of coram nobis relief	Clerk’s failure to promptly notify Scott of the order excused the late filing	No absolute duty exists to notify; appellant must exercise diligence and timely file	Denied — Scott failed to show good cause for the late notice of appeal

Meadows v. State, 2012 Ark. 374 (recognizing right to appeal denial of coram nobis)
Perry v. State, 2010 Ark. 84 (belated appeal requires showing of good cause)
Wesley v. Harmon, 2010 Ark. 21 (parties must exercise reasonable diligence to track case status)
Tarry v. State, 346 Ark. 267 (pro se litigants get no special procedural indulgence)
Bannister v. State, 2013 Ark. 412 (party, not clerk, responsible for perfecting appeal)