United States v. Morgan
346 U.S. 502 (1954)
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Rule of Law:
A United States District Court has the power, under the All Writs Act, to issue a writ of error coram nobis to vacate a conviction for which the sentence has been fully served, where the conviction was marred by a fundamental error and continues to have adverse legal consequences.
Facts:
- In 1939, Robert Morgan, then nineteen years old, pleaded guilty to a federal charge in the U.S. District Court for the Northern District of New York.
- Morgan alleges he was not represented by counsel, was not advised of his right to counsel, and did not competently waive this right.
- He was sentenced to a four-year term of imprisonment, which he fully served.
- In 1950, a New York state court convicted Morgan of a separate state crime.
- Due to his prior 1939 federal conviction, the New York court sentenced Morgan to an enhanced, longer prison term under the state's second offender law.
- Morgan is currently incarcerated in a New York state prison serving this enhanced sentence.
Procedural Posture:
- Robert Morgan filed an application for a writ of error coram nobis in the United States District Court for the Northern District of New York, the court of his 1939 conviction.
- The District Court treated the application as a motion under 28 U.S.C. § 2255 and dismissed it for lack of jurisdiction because Morgan was no longer in custody under its sentence.
- Morgan, as appellant, appealed to the United States Court of Appeals for the Second Circuit.
- The Court of Appeals reversed the District Court's decision, holding that § 2255 did not abolish the common law writ of coram nobis, and remanded the case for a hearing on the merits.
- The United States, as petitioner, was granted a writ of certiorari by the United States Supreme Court.
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Issue:
Does a United States District Court have the power, through a motion in the nature of a writ of error coram nobis, to vacate a federal conviction and sentence after the petitioner has fully served the term of imprisonment?
Opinions:
Majority - Mr. Justice Reed
Yes. A United States District Court has the power to grant a motion in the nature of a writ of error coram nobis to vacate a conviction even after the sentence has been served. This power derives from the All Writs Act, which authorizes federal courts to issue writs necessary to achieve justice. The writ of coram nobis was a common law remedy used to correct fundamental errors of fact not apparent on the record, and it is available to challenge a conviction where no other remedy exists. The Court reasoned that although the sentence was served, the conviction had 'persistent consequences,' such as the enhanced state sentence Morgan was now serving. The Court held that 28 U.S.C. § 2255, which requires a petitioner to be 'in custody,' did not eliminate coram nobis as a remedy for those no longer in federal custody but still suffering from an allegedly unconstitutional conviction. Denying a forum to correct a fundamental constitutional error, like the denial of the right to counsel established in Johnson v. Zerbst, would allow a wrong to stand uncorrected.
Dissenting - Mr. Justice Minton
No. A United States District Court does not have the power to issue a writ of error coram nobis in this situation. The dissent argues that the All Writs Act does not apply because the writ is not being issued 'in aid of' the District Court's jurisdiction, which was exhausted once Morgan completed his sentence. Furthermore, the ancient writ of coram nobis is no longer 'agreeable to the usages and principles of law' because Congress intended for 28 U.S.C. § 2255 to be the comprehensive modern remedy for collateral attacks on federal convictions. The Reviser's Note to § 2255 explicitly states that it simplifies the procedure 'in the nature of the ancient writ of error coram nobis.' Since Congress limited § 2255 relief to prisoners 'in custody,' the Court should not resurrect an obsolete writ to circumvent this clear legislative limitation and undermine the finality of judgments.
Analysis:
This case is significant for affirming the continued viability of the common law writ of error coram nobis in federal courts as a post-conviction remedy. It fills a critical gap in the law by providing a mechanism for individuals who are no longer 'in custody' under a federal sentence to challenge their convictions. The decision establishes that ongoing collateral consequences, such as sentence enhancements in subsequent cases, are sufficient grounds to invoke this extraordinary remedy. By prioritizing the correction of fundamental constitutional errors over the finality of judgments, United States v. Morgan ensures a judicial forum remains available for those suffering lingering harms from an allegedly invalid conviction, even after their sentence is complete.
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