Williams v. State, 485 S.W.3d 254

Williams was convicted in 2008 by a jury of two counts aggravated robbery, two counts terroristic threatening in the first degree, theft of property, and battery in the third degree, and sentenced as a habitual offender to 360 months.
He represented himself at trial with standby counsel; appellate counsel filed a direct appeal that argued trial court error in allowing self-representation; the appellate court affirmed and this court denied review.
Williams seeks to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis after affirmance, requiring leave from the Supreme Court for such petitions.
Coram-nobis relief is rare and available only to address fundamental errors not discovered or raised earlier, in four limited categories.
He alleges insanity at the time of the offenses or trial and faults the mental-health evaluation and counsel for not informing him of the evaluation results; he also raises ineffective assistance claims.
The court denied Williams’s petition, holding that coram-nobis relief was not warranted on the asserted grounds and that ineffective assistance claims are not cognizable in coram-nobis proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether coram-nobis relief is available for insanity claims after appeal	Williams contends insanity at trial invalidates judgment and merits relief.	Court requires compelling, extra-record facts to warrant coram-nobis relief, with strong presumption of validity.	Petition denied; insanity grounds not proven.
Whether the petition asserts a cognizable basis for coram-nobis relief based on mental-health evaluation	Evaluation was not performed as claimed and affected mental-status issues.	Record shows evaluation and does not reveal undiscoverable insanity facts.	denied; insufficient undiscoverable facts shown
Whether Williams can raise ineffective-assistance claims in a coram-nobis proceeding	Counsel failed to inform of evaluation and withdrew plea; ineffecive assistance warrants relief.	Ineffective assistance is not cognizable in coram-nobis proceedings.	Petition denied on this basis
Whether any other basis supports coram-nobis relief or the reinvestment petition	There were undisclosed facts warranting relief outside the record.	Record supports validity of judgment and no new facts establish grounds.	Petition denied; no basis to grant writ

Newman v. State, 2009 Ark. 539 (Ark. 2009) (permits coram-nobis relief only with leave and compelling facts)
Howard v. State, 2012 Ark. 177 (Ark. 2012) (lists four categories for coram-nobis relief and standards)
Westerman v. State, 2015 Ark. 69 (Ark. 2015) (presumption of valid judgment; limitations of coram-nobis)
Noble v. State, 2015 Ark. 215 (Ark. 2015) (burden to show insanity and that issue could have been raised earlier)
Millsap v. State, 2014 Ark. 493 (Ark. 2014) (full disclosure of facts required for coram-nobis petition)
Roberts v. State, 2013 Ark. 56 (Ark. 2013) (burden on petitioner to show fundamental error extrinsic to record)
State v. Larimore, 341 Ark. 397 (Ark. 2000) (coram-nobis generally available for extraordinary relief)
Ridgeway v. State, 389 S.W.2d 617 (1965) (mental examination information previously before trial cannot be reconsidered in coram-nobis)