Wright v. State
456 S.W.3d 371
Ark.2015Background
- Danny Wright pled guilty in 2009 to first-degree kidnapping and stalking and received an aggregate 180-month sentence with a 60-month sentence suspended.
- In 2011 Wright moved to withdraw his guilty plea (a Rule 37.1 matter); the trial court denied relief, he appealed, then voluntarily dismissed the appeal in 2012.
- In 2013 Wright filed a pro se petition for a writ of error coram nobis alleging his plea was "coerced, however subtly," by retained counsel’s threats of a life sentence if he went to trial.
- Wright also alleged counsel misadvised him about parole eligibility, claiming a 1995 Texas attempted-murder conviction would require him to serve 100% of his sentence rather than the one-third he was told.
- The trial court denied coram nobis relief; Wright appealed, arguing coercion and withholding of information regarding parole eligibility and prior conviction.
- The Supreme Court of Arkansas reviewed whether the trial court abused its discretion in denying the coram nobis petition and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Wright's plea was coerced such that coram nobis relief is warranted | Wright: Counsel’s threats he would get life if he went to trial coerced the guilty plea | State: Mere advice about harsher penalties does not constitute coercion; no threats producing fear/duress alleged | Denied — no showing of coercion (fear, duress, or threats of mob violence) sufficient for coram nobis |
| Whether misinformation about parole eligibility/supporting facts warrant coram nobis | Wright: He was told he’d be eligible after serving one-third; later learned a 1995 Texas conviction required serving 100% | State: Parole statutes and prior-conviction status were not hidden; facts were not extrinsic to the record and do not fit coram-nobis categories | Denied — parole-eligibility and prior-conviction facts were not extrinsic and are not coram-nobis grounds |
| Whether ineffective assistance of counsel claims are cognizable in coram-nobis | Wright: Alleged counsel threats and bad advice about parole amount to ineffective assistance | State: Ineffective-assistance claims must be raised under Rule 37.1, not by coram nobis | Denied — ineffective-assistance claims are not cognizable in coram-nobis; should be raised under Rule 37.1 |
| Whether the trial court abused its discretion in denying the writ | Wright: Trial court erred in rejecting his factual allegations as grounds for the writ | State: Court acted within discretion given coram-nobis standards and the record | Affirmed — no abuse of discretion; petition failed to allege an extrinsic, fundamental factual error |
Key Cases Cited
- Wilburn v. State, 2014 Ark. 394, 441 S.W.3d 29 (standard of review for coram-nobis denial is abuse of discretion)
- Millsap v. State, 2014 Ark. 493, 447 S.W.3d 121 (coram-nobis is an extraordinary remedy; strong presumption of validity)
- Schrader v. State, 2014 Ark. 379, 441 S.W.3d 1 (ineffective-assistance claims challenging a plea belong in Rule 37.1, not coram-nobis)
- McArthur v. State, 2014 Ark. 367, 439 S.W.3d 681 (coram-nobis is not a substitute for timely Rule 37.1 petitions)
- Nelson v. State, 2014 Ark. 91, 431 S.W.3d 852 (advice that trial may bring harsher penalty is not coercion for coram-nobis)
- Weekly v. State, 2014 Ark. 365, 440 S.W.3d 341 (coram-nobis cognizable coercion claims require fear, duress, or threats of mob violence)