Summary
affirming denial of petition for writ of error coram nobis because sex-offender registration under Arkansas statute was collateral consequence of conviction
Summary of this case from Hudson v. MinnesotaOpinion
No. 16-3059
02-09-2017
United States of America Plaintiff - Appellee v. Conrad Eliot Dickson Defendant - Appellant
Appeal from United States District Court for the Western District of Arkansas - Fayetteville [Unpublished] Before WOLLMAN, MURPHY, and GRUENDER, Circuit Judges. PER CURIAM.
Conrad Dickson appeals after the district court denied his petition for a writ of error coram nobis, in which he sought to vacate a prior conviction for which he had served his sentence. His petition asserted an ineffective-assistance claim and other claims that were essentially considered and resolved in a prior 28 U.S.C. § 2255 motion. Following careful de novo review, we conclude that the district court properly denied Dickson's petition. See United States v. Camacho-Bordes, 94 F.3d 1168, 1173 (8th Cir. 1996) (reviewing de novo district court's legal conclusions in denying coram nobis relief); see also Chaidez v. United States, 133 S.Ct. 1103, 1108 & n.5 (2013) (discussing the contours of the Sixth Amendment right to counsel and labeling sex-offender registration as one of the "collateral consequences" of a conviction); George v. Black, 732 F.2d 108, 110 (8th Cir. 1984) (determining that accused need only be informed of direct consequences of guilty plea); Azzone v. United States, 341 F.2d 417, 418-19 (8th Cir. 1965) (per curiam) (noting that, if sentence has been served, individual may file petition for writ of error coram nobis in attempt to vacate prior conviction, while also holding that a petitioner is not entitled to review of issues that were considered and resolved in a prior § 2255 motion). Accordingly, we affirm. See 8th Cir. R. 47B.
The Honorable Timothy L. Brooks, United States District Judge for the Western District of Arkansas, partially adopting the report and recommendations of the Honorable Erin L. Setser, United States Magistrate Judge for the Western District of Arkansas. --------