United States v. Ochoa – Do It For The Caselaw

Holding: The Ninth Circuit affirmed the district court's denial of the petition for a writ of error coram nobis.
Standard: Abuse of discretion for denial of evidentiary hearing; conjunctive requirements for coram nobis relief
Vote: The panel unanimously concluded the case was suitable for decision without oral argument.
Practical effect: The decision reinforces the high bar for coram nobis relief and limits the ability of prisoners to obtain evidentiary hearings based on unsupported claims of new evidence.

United States v. Ochoa

June 1, 2026 ·25-6296 ·Unpublished · By James Taylor

The Ninth Circuit affirmed the district court's denial of a petition for a writ of error coram nobis. The panel held that the appellant failed to provide valid reasons for not challenging the restitution order earlier and offered only conclusory allegations.

Background

Armando Pablo Ochoa appealed pro se from the district court’s order granting in part and denying in part his petition for a writ of error coram nobis. Ochoa contended that the district court erred in denying relief without holding an evidentiary hearing. He asserted that the victim casino had been fully compensated by a supplemental insurance policy but offered no particulars regarding the policy.

The court’s reasoning

The panel agreed with the district court that Ochoa failed to show valid reasons for not challenging the restitution order earlier. The court cited United States v. Riedl and Matus-Leva v. United States regarding the conjunctive requirements for coram nobis relief. Regarding the evidentiary hearing, the court found no abuse of discretion, noting that mere conclusory allegations do not warrant a hearing. The court emphasized that courts should not allow prisoners to use federal discovery for fishing expeditions to investigate mere speculation.

What it means going forward

The decision reinforces the high bar for coram nobis relief and limits the ability of prisoners to obtain evidentiary hearings based on unsupported claims of new evidence.