White v. State, 2015 Ark. 151

Herman L. White shot at an Arkansas State Police corporal during a 2012 traffic stop; corporal’s vest stopped at least one round and returned fire; White was on probation.
White pled guilty in November 2013 to first-degree battery of a law-enforcement officer (Class Y) and possession of a firearm by certain persons (Class B); sentenced as a habitual offender to concurrent 60- and 40-year terms.
Two psychological evaluations had been performed during the case; White alleges limited education, mental deficits, and reliance on family advice.
After plea, White learned he was required to serve 100% of the 60-year sentence (no parole eligibility per DOC computation).
In March 2014 White filed a petition for writ of error coram nobis asserting his plea was coerced and that counsel was ineffective because he was told he would be eligible for parole; the circuit court denied the petition.
White appealed the denial; the Supreme Court affirmed, holding coram nobis was not the proper vehicle for ineffective-assistance or plea-voluntariness claims and White’s allegations did not show coercion of the sort remediable by coram nobis.

Issue	White's Argument	State's Argument	Held
Whether coram nobis could be used to attack plea voluntariness based on counsel’s erroneous advice about parole	White: counsel’s incorrect parole advice and family pressure rendered plea involuntary/coerced	State: coram nobis is not a substitute for Rule 37 ineffective-assistance claims; plea colloquy showed understanding of parole decision by DOC	Denied — coram nobis inappropriate for ineffective-assistance or ordinary plea-voluntariness claims
Whether White’s alleged reliance on family advice amounted to coercion	White: heavily relied on sisters’ advice who told him he’d be eligible for parole	State: mere mistaken advice by family or counsel is not coercion; no threats or duress alleged	Denied — allegations do not meet legal definition of coercion
Whether the circuit court abused its discretion in denying coram nobis	White: court should set aside judgment due to fundamental error affecting plea	State: circuit court’s finding supported by plea colloquy and law limiting coram nobis	No abuse of discretion; denial affirmed
Whether ineffective-assistance-of-counsel claims are cognizable in coram nobis proceedings	White: framed claim partly as ineffective assistance to excuse missing Rule 37 window	State: such claims must be brought under Rule 37, not coram nobis	Court: ineffective-assistance claims not cognizable in coram nobis under Arkansas law

Howard v. State, 403 S.W.3d 38 (Ark. 2012) (explains rarity and purpose of coram nobis relief)
Nelson v. State, 431 S.W.3d 852 (Ark. 2014) (coram nobis not a substitute for Rule 37 challenges to guilty pleas)
State v. Tejeda-Acosta, 427 S.W.3d 673 (Ark. 2013) (ineffective-assistance claims not cognizable in coram nobis)