Smith v. State, 491 S.W.3d 463

James E. Smith was convicted by a jury of two counts of rape of victims under fourteen and sentenced to two consecutive 20-year terms; convictions affirmed on direct appeal.
Smith filed multiple postconviction challenges (Rule 37.1 and several coram nobis petitions); earlier petitions were denied or dismissed as successive.
In this fourth pro se application for leave to file a coram nobis petition, Smith alleges the trial court lacked subject-matter jurisdiction because (1) the arrest warrant was invalid (not signed by the court) and (2) the criminal information was deficient (not signed by prosecutor or filed by circuit clerk).
Smith also claims his trial counsel conspired with the prosecutor and court to conceal these defects; he moved for appointment of counsel to pursue relief.
The Arkansas Supreme Court treated the filing as a request to reinvest jurisdiction to allow the trial court to consider a coram nobis petition and denied relief, finding the claims not cognizable in coram nobis and otherwise meritless; the motion for counsel was ruled moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether alleged defects in the arrest warrant and information render conviction subject-matter jurisdictionally invalid	Smith: warrant unsigned; information unsigned/unfiled — therefore trial court lacked subject-matter jurisdiction and conviction is void	State: deficiencies in warrant or information are trial defects, discoverable at trial, and do not deprive court of subject-matter jurisdiction	Denied — alleged defects were not extrinsic facts for coram nobis and would not defeat subject-matter jurisdiction
Whether an illegal arrest bars subsequent prosecution or a valid conviction	Smith: invalid arrest warrants the overturning of conviction	State: illegal arrest, without more, does not bar prosecution or vitiate a conviction; suppression remedy is available if warranted	Denied — illegal arrest alone does not invalidate conviction
Whether counsel and court conspired to conceal jurisdictional defects	Smith: counsel and court knowingly concealed defects to deprive him of jurisdictional defense	State: no evidentiary support; claim is meritless	Denied — no evidence; claim insufficient for coram nobis
Whether appointment of counsel is warranted for this coram nobis application	Smith: requested appointed counsel to litigate the coram nobis petition	State/Court: petition without merit so appointment unnecessary	Motion for appointment of counsel held moot

Sawyer v. State, 327 Ark. 421 (1997) (sets sufficiency standard for a criminal information)
Biggers v. State, 317 Ark. 414 (1994) (illegal arrest does not bar prosecution or automatically invalidate a conviction)
O'Riordan v. State, 281 Ark. 424 (1984) (invalid arrest may implicate suppression but not discharge from prosecution)