Williams v. State ‎(2)‎, 2017 Ark. 26

Phillip D. Williams was convicted by a Pulaski County jury in 2001 of capital-felony murder, two counts of aggravated robbery, and misdemeanor theft; he was sentenced to life without parole and concurrent twenty-year terms; this Court affirmed on direct appeal.
Williams filed a pro se petition asking the Supreme Court to reinvest jurisdiction in the trial court so he could pursue a writ of error coram nobis based on newly discovered evidence.
Williams appended an affidavit from trial witness Kareem Holloway recanting his trial testimony and giving a different account of events.
Coram nobis is an extraordinary post-conviction remedy that requires proof of a fundamental, extrinsic factual error that, without the petitioner’s fault, was not brought to the court’s attention before judgment.
Recanted testimony is generally considered a direct attack on the judgment and, standing alone, is not cognizable in coram-nobis proceedings in Arkansas.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Court should reinvest jurisdiction to allow a coram-nobis petition	Williams: Holloway’s affidavit is newly discovered evidence that undermines trial evidence and warrants coram nobis relief	State: Holloway’s affidavit is a recantation that directly attacks the judgment and is not a proper basis for coram nobis	Denied — recanted testimony is not cognizable in coram-nobis and cannot be used to contradict adjudicated facts
Whether recanted testimony qualifies as "newly discovered evidence" for coram nobis	Williams: Labels Holloway’s affidavit as newly discovered evidence supporting his account	State: Recantation does not change that it is a direct attack on the conviction; coram nobis is not the vehicle	Held: Recantation is not a ground for coram nobis regardless of label
Scope of coram nobis categories	Williams: Implicitly urges expansion to encompass his claim	State: Coram nobis is limited to fundamental extrinsic errors and established categories unless a procedural gap exists	Held: Coram nobis remains limited; categories may expand only if necessary to fill a procedural due-process gap; not met here
Proper remedy for challenging trial evidence sufficiency	Williams: Seeks collateral coram-nobis review	State: Sufficiency and credibility challenges belong to trial record and direct appeal	Held: Challenges to trial evidence are for trial and direct appeal; coram nobis inappropriate

Newman v. State, 2009 Ark. 539, 354 S.W.3d 61 (permission required to reinvest trial court jurisdiction for coram nobis)
State v. Larimore, 341 Ark. 397, 17 S.W.3d 87 (coram nobis is an extraordinarily rare remedy)
Westerman v. State, 2015 Ark. 69, 456 S.W.3d 374 (strong presumption that conviction is valid in coram-nobis proceedings)
Roberts v. State, 2013 Ark. 56, 425 S.W.3d 771 (petitioner bears burden to show fundamental extrinsic error)
Howard v. State, 2012 Ark. 177, 403 S.W.3d 38 (enumeration of common categories for coram nobis relief)
Smith v. State, 200 Ark. 767, 140 S.W.2d 675 (coram nobis may not be used to contradict adjudicated facts; recantation insufficient)
Riley v. State, 2015 Ark. 232 (victim’s recantation does not warrant coram nobis)
Malone v. State, 294 Ark. 127, 741 S.W.2d 246 (affidavit recanting trial testimony is a direct challenge to the judgment)
Washington v. State, 2014 Ark. 370, 439 S.W.3d 686 (sufficiency of evidence is resolved at trial and on direct appeal)

Petition denied.