Bryant v. State

Summary

The Arkansas Supreme Court denied Tracy Lee Bryant’s motion for belated appeal from the denial of his petition for a writ of error coram nobis. The court held that Bryant’s claims concerning competency, coercion, and ineffective assistance of counsel either lacked supporting facts or were not cognizable in coram nobis proceedings, while a dissent argued that the court lacked jurisdiction because no notice of appeal had been filed.

Holdings

1. The court may decline to consider the reason for an untimely or missing notice of appeal when the underlying postconviction petition is clearly wholly without merit and the petitioner could not prevail on appeal.
2. Bryant failed to state a legally sufficient claim for coram-nobis relief because he alleged no facts demonstrating a fundamental error of fact extrinsic to the record that would have prevented rendition of the judgment.
3. An ineffective-assistance-of-counsel claim is not a ground for a writ of error coram nobis.
4. Bryant's allegations concerning mental illness, failure to obtain a mental evaluation, and possible incompetence did not support coram-nobis relief because he alleged no extrinsic facts showing that he was incompetent to enter his guilty plea or that such facts were unknown at the time of judgment.
5. Bryant's coerced-plea claim did not support coram-nobis relief because he alleged no facts showing that his plea resulted from fear, duress, or threats of mob violence.

Questions Presented

1. Whether Bryant should be permitted to pursue a belated appeal despite the absence of a notice of appeal.
2. Whether Bryant's coram-nobis petition stated a potentially meritorious claim that would justify allowing the appeal to proceed.
3. Whether ineffective assistance of counsel, alleged incompetence or failure to obtain a mental evaluation, and alleged involuntariness or coercion of a guilty plea supported coram-nobis relief.

Disposition

other