Watson v. State, 2017 Ark. 56

In 2005 Jason N. Watson pleaded guilty to capital murder and was sentenced to life without parole.
In January 2016 Watson filed a pro se petition for writ of error coram nobis alleging incompetence at plea, coercion into the plea, and that his plea was not knowing and voluntary; he also interspersed sufficiency-of-evidence claims.
The trial court held a hearing, denied the coram nobis petition, and Watson appealed and moved to supplement the record with additional mental-health evidence.
The Supreme Court of Arkansas reviewed whether the coram nobis denial was an abuse of discretion and whether Watson’s claims fit within the narrow categories for coram nobis relief.
The court found Watson’s sufficiency claims foreclosed by his guilty plea, his voluntariness claims better suited to Rule 37.1, his coercion allegations insufficient as a matter of law, his incompetence claim unsupported by new facts, and his petition untimely without due diligence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competency at time of plea (insanity)	Watson: he was mentally incompetent when he entered the guilty plea; prior evaluation was inadequate and overlooked mitigating mental-health history	State: Watson failed to show a previously unknown or unknowable fact establishing incompetence; record did not support coram nobis relief	Denied — petitioner failed to present new, extrinsic facts showing incompetence; claim insufficient
Coercion/voluntariness of plea	Watson: plea coerced by counsel’s warnings and by his mental state; plea not knowing or voluntary	State: alleged pressure from counsel’s advice about harsher sentence is not coercion; voluntariness/validity of plea belongs under Rule 37.1	Denied — allegations do not meet definition of coercion; voluntariness challenges belong to Rule 37.1
Sufficiency of the evidence	Watson: interspersed assertions evidence was insufficient to prove guilt	State: guilty plea waives sufficiency challenges; coram nobis is not a vehicle for sufficiency review	Rejected — sufficiency claims not cognizable in coram nobis; plea waived guilt challenge
Timeliness / due diligence	Watson: waited ~10 years before filing but relied on attached materials	State: petitioner lacked due diligence and offered no valid excuse for delay	Denied — delay unexplained; petitioner did not satisfy due-diligence requirements

Millsap v. State, 449 S.W.3d 701 (Ark. 2014) (appeal will be dismissed when appellant could not prevail on postconviction order)
Nelson v. State, 431 S.W.3d 852 (Ark. 2014) (coram nobis is not a substitute for Rule 37.1; abuse-of-discretion standard)
State v. Larimore, 17 S.W.3d 87 (Ark. 2000) (coram nobis is an extraordinary remedy)
Roberts v. State, 425 S.W.3d 771 (Ark. 2013) (petitioner must demonstrate a fundamental error of fact extrinsic to the record)
White v. State, 460 S.W.3d 285 (Ark. 2015) (warnings about possible harsher sentence do not amount to coercion)