Terrance O. Coley v. Commonwealth of Virginia, et al.

Summary

The United States District Court for the Eastern District of Virginia dismissed Terrance O. Coley's petition for a writ of coram vobis. The court held that it lacked jurisdiction to alter state-court sentences and that coram nobis relief was unavailable because Coley remained in custody and the federal court had not imposed the challenged sentences.

Holdings

1. A federal district court lacks subject matter jurisdiction to issue a writ of coram nobis or coram vobis to alter a state criminal conviction or sentence because the federal court did not impose the challenged judgment.
2. A petitioner who remains in custody on the challenged sentences may not use coram nobis or coram vobis as the vehicle for relief.

Questions Presented

1. Whether a federal district court has jurisdiction to issue a writ of coram nobis or coram vobis altering sentences imposed by a state court.
2. Whether Coley could use coram nobis or coram vobis relief while remaining in custody on the challenged sentences.

Disposition

dismissed