Westerman v. State, 2015 Ark. 69

Westerman pled guilty to one count of rape and received a life sentence; remaining rape counts were nolle prosequi in exchange for his cooperation against his wife.
Westerman filed a pro se petition for writ of error coram nobis on April 1, 2013 claiming insanity at plea and coercion.
Circuit court denied the petition without a hearing and Westerman appealed, arguing abuse of discretion.
Sentencing court previously found Westerman competent to stand trial and to assist defense.
Westerman contends he did not receive the ordered 30-day inpatient evaluation and that the plea was coerced.
The Arkansas Supreme Court affirmed the circuit court’s denial, holding no hearing was required and the claims were not cognizable or substantiated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Insanity at time of plea justifies coram nobis	Westerman asserts insanity at plea.	State argues insanity was already addressed by sentencing court.	No error; insanity claim precluded by prior competency ruling.
Coerced guilty plea	Westerman claims counsel coerced plea with threat of more life sentences.	Plea based on potential harsher sentence is not coercion.	Not cognizable in coram nobis; results from ineffective assistance claim.
Due diligence in filing coram nobis	Westerman acted diligently, petition timely.	Due diligence required; not addressed if petition lacks cognizable basis.	Court need not address due diligence given lack of cognizable basis.

Ridgeway v. State, 239 Ark 377 (Ark. 1965) (insanity claims must be brought before judgment if raised earlier)
Roberts v. State, 2013 Ark. 56, 425 S.W.3d 771 (Ark. 2013) (strong presumption of validity in coram nobis proceedings; addressing insane plea/coercion issues)
Nelson v. State, 2014 Ark. 91, 431 S.W.3d 852 (Ark. 2014) (coram nobis not available for ineffective-assistance claims; coercion not cognizable)
Echols v. State, 354 Ark. 414, 125 S.W.3d 153 (Ark. 2003) (due diligence requirement for coram nobis applications; cognizable basis needed)