State v. Tejeda-Acosta
2013 Ark. 217
| Ark. | 2013Background
- Appellee Tejeda-Acosta pled guilty on December 6, 2010 to two felonies under Act 346, with a plea deal including probation and testimony against codefendants.
- After pleading, ICE detained him for deportation proceedings based on alleged immigration consequences of his guilty pleas, despite this court noting that such pleas under Act 346 are not convictions for immigration purposes.
- Appellee petitioned for writ of error coram nobis on November 14, 2011, alleging lack of immigration-consequences advice by counsel under Padilla; circuit court granted the writ and vacated the pleas and sentence.
- State appealed arguing the circuit court improperly expanded coram-nobis grounds to include ineffective-assistance claims, contrary to Estrada v. State.
- Estrada held that ineffective-assistance claims are not cognizable in coram-nobis proceedings and must be pursued under Rule 37.1, not coram nobis.
- The Arkansas Supreme Court reversed, holding that coram-nobis relief cannot be expanded to address ineffective assistance, and time-bar rules for Rule 37.1 remain jurisdictional.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether coram-nobis grounds were improperly expanded to include ineffective assistance. | State argues Estrada bars such expansion; relief for IAC cannot be sought via coram-nobis. | Tejeda-Acosta contends distinctions from Estrada justify relief under coerced-plea theory and Padilla-based claims. | Court held improper expansion; reverse writ order. |
Key Cases Cited
- Estrada v. State, 2011 Ark. 479 (Ark. 2011) (rejected expanding coram nobis to include ineffective-assistance claims under Padilla)
- Grant v. State, 2010 Ark. 286 (Ark. 2010) (coram nobis not a substitute for Rule 37.1 relief)
- Lynn v. State, 2012 Ark. 6 (Ark. 2012) (Act 346 plea generally not a conviction for immigration purposes)
- McDonald v. State, 285 Ark. 482 (Ark. 1985) (jurisdictional time limits reinforced for postconviction relief)
- Haywood v. State, 288 Ark. 266 (Ark. 1986) (plea-based claims cognizable under Hill/Strickland framework)
- Heard v. State, 2012 Ark. 67 (Ark. 2012) (cognizable plea claims governed by Strickland framework)