Nathaniel Coleman was convicted in 1985 of conspiracy to cause a government witness to be unavailable and obstruction of justice following the murder of a witness in his drug trial. He was sentenced to life imprisonment in 1987, and his conviction was affirmed on direct appeal. Over the years, Coleman filed numerous challenges to his conviction and sentence, including motions under 28 U.S.C. § 2255 and applications under § 2244, all of which were unsuccessful. After being released on parole in 2019 and having his supervised release terminated in 2023, Coleman filed a petition for a writ of error coram nobis in 2024. He argued that he was entitled to relief based on information he claimed to have received in 1996 via a Freedom of Information Act request, which allegedly revealed that the government withheld exculpatory evidence, including a fingerprint report that did not match him. The District Court denied the petition, and Coleman appealed.
The Third Circuit exercised de novo review and noted that a writ of error coram nobis is an extraordinary remedy available only in the most limited circumstances. To succeed, a petitioner must prove five elements: they are no longer in custody, suffer continuing consequences from the conviction, provide sound reasons for failing to seek relief earlier, had no available remedy at the time of trial, and assert errors of a fundamental kind. The court found that Coleman's petition failed to meet these standards. Specifically, the court emphasized that Coleman's claim relied on information he had allegedly received over 25 years ago, which he had already attempted to use in a prior proceeding to seek authorization for a second or successive § 2255 motion. The court cited United States v. Rhines to clarify that a petitioner cannot resort to a writ of error coram nobis simply because they cannot meet the standard for filing a second or successive § 2255 motion. Because the appeal failed to present a substantial question, the court granted the Government's motion for summary affirmance.
The decision confirms that the writ of error coram nobis cannot be used as a substitute for the procedural hurdles of successive habeas petitions. Coleman's conviction and sentence remain undisturbed, and the ruling reinforces the finality of judgments in cases where the alleged error has been previously litigated or where the petitioner cannot demonstrate a fundamental error that was unavailable for challenge at the time of trial. No remand instructions were issued as the case was summarily affirmed.
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