Melvin Jefferson v. State of Arkansas

Summary

The court affirmed the denial of Jefferson’s petition because a request for audita querela relief challenging a criminal judgment is properly treated as a coram nobis petition, and Rule 60(k) does not authorize a separate audita querela procedure. Jefferson’s claims concerning the guilty-plea colloquy, jurisdiction, charging instrument, and parole eligibility either were not cognizable in coram nobis or should have been raised through a timely postconviction proceeding. The denial was reviewed for abuse of discretion, and no hearing was required because the petition lacked merit.