Robert Munnerlyn v. State of Arkansas

Summary

The court denied Munnerlyn's request to pursue coram nobis relief or an untimely Rule 37 petition because his challenge to the adequacy of his Miranda warnings concerned an issue that could have been raised at trial and did not establish a fact extrinsic to the record or a defect rendering the conviction void. The court also held that the later clarification of the required warnings could not be applied retroactively in this untimely collateral proceeding. Justice Hart concurred in the result but would have resolved the Rule 37 claim on res judicata grounds because the same Miranda issue had already been rejected in Munnerlyn's earlier petition.