Supreme Court of Arkansas

Frank Franklin, Petitioner v. State of Arkansas, Respondent

December 3, 20152015 Ark. LEXIS 637

Summary

The court denied Franklin's petition to reinvest the trial court with jurisdiction to consider a writ of error coram nobis and his related motion. It held that an alleged speedy-trial violation is trial error, not an extrinsic factual error cognizable in a coram-nobis proceeding. The court emphasized that coram nobis is limited to extraordinary circumstances and four recognized categories of fundamental error.