Kenneth Charles McNeil v. United States

The All-Writs Act provides federal courts the au­ thority to issue writs in aid of their jurisdiction, “when no other remedy will suffice." DiBella v. United States, 369 U.S. 121, 125 n.4 (1962). The writ of error coram nobis is the only remedy available to former federal prisoners who seek correction of a conviction after completion of the sentence. Coram nobis “is an equita­ ble means to obtain relief from a judgment.” United States v. Denedo, 904, 913 (2009). Federal courts of eq­ uity decided equitable claims until 1938, when Con­ gress merged law and equity into a single civil juris­ diction. If courts of equity were authorized to provide equitable relief to former prisoners, Congress pro­ vided no expressed intent to repeal this authority when it promulgated the civil rules. And this Court has long held that repeals by implication are not fa­ vored. The question presented is: Whether federal courts of equity had jurisdiction to correct criminal judgments after completion of the sentence, and, if so, whether federal courts violate the All-Writs Act in coram nobis proceedings by relying upon 28 U.S.C. § 2255 evidentiary hearing procedures instead of the courts of equity hearing procedures.