Supreme Court of Arkansas

Bobby Charles Nelson, Appellant v. State of Arkansas, Appellee

February 27, 20142014 Ark. LEXIS 146

Summary

The court affirmed the denial of Nelson’s coram nobis petition because his allegations that counsel coerced his guilty plea, misrepresented parole eligibility, and operated under a conflict of interest were substantively ineffective-assistance claims, which are not cognizable in coram nobis proceedings. Because the petition did not state a cognizable basis for relief, the circuit court did not abuse its discretion by denying the petition without an evidentiary hearing. Justice Baker, joined by Justices Hart and Hoofman, dissented and would have remanded for a hearing because the alleged undisclosed conflict and resulting pressure could support a cognizable coerced-plea claim.