## Facts

- In 1939, Robert Patrick Morgan pleaded guilty in the U.S. District Court for the Northern District of New York and received a four-year federal sentence, which he fully served.
- In 1950, Morgan was convicted in New York state court and sentenced as a second offender based on the prior federal conviction; he was incarcerated under the state sentence.
- Morgan sought to vacate the 1939 federal conviction in the original federal sentencing court, alleging he was denied the Sixth Amendment right to counsel and did not competently waive counsel.
- The district court treated the filing as a motion under 28 U.S.C. § 2255 and denied relief for lack of jurisdiction because Morgan was no longer “in custody” under the federal sentence.
- The Second Circuit reversed, holding the application could proceed as a motion in the nature of the common-law writ of error coram nobis and remanded for further proceedings.

## Issues

1. Whether a federal district court may, under the All Writs Act, 28 U.S.C. § 1651(a), entertain a petition in the nature of coram nobis to vacate its criminal judgment after the sentence has been fully served.
2. Whether § 2255, Federal Rule of Civil Procedure 60(b), or Federal Rule of Criminal Procedure 35 displaces coram nobis in this setting.
3. Whether a court may treat an imprecisely labeled post-conviction filing as seeking coram nobis relief when it alleges a fundamental constitutional defect and no other remedy is available.

## Decision

- The Supreme Court affirmed the Second Circuit, holding that the district court had power under 28 U.S.C. § 1651(a) to issue coram nobis in a criminal case and to vacate its judgment after the sentence was served.
- The Court held Morgan’s papers could be treated as a motion in the nature of coram nobis notwithstanding labeling uncertainty.
- The Court held Rule 60(b) (abolishing coram nobis in civil cases) did not apply to this criminal proceeding.
- The Court held Rule 35 was inapplicable because it concerns correction of sentences and did not provide a vehicle to attack a conviction after the sentence was completed.
- The Court held § 2255 did not supersede all other remedies; because § 2255 requires custody, it did not bar coram nobis relief for a completed sentence with continuing consequences.
- The Court did not decide the validity of Morgan’s 1939 conviction; it required that he be given an opportunity in district court to attempt to prove the alleged constitutional violation.

## Legal Principles

- The All Writs Act authorizes federal courts to issue extraordinary writs, including coram nobis, when necessary or appropriate in aid of their jurisdiction.
- Coram nobis is available in criminal cases to correct errors “of the most fundamental character,” including alleged denial of the right to counsel, even after the defendant has served the sentence.
- A coram nobis proceeding is treated as a step in the criminal case, not a separate civil action.
- Post-sentence collateral relief may be justified when the conviction produces continuing legal consequences and no other remedy is available.
- Relief by coram nobis is exceptional and generally requires (i) absence of another remedy, and (ii) sound reasons for not seeking earlier relief.

## Conclusion

The Court recognized coram nobis as a narrow but available federal remedy to attack an allegedly unconstitutional federal conviction after custody ends, preserving judicial power under the All Writs Act to address fundamental errors that carry continuing consequences.


United States v. Morgan, 346 U.S. 502 (1954)