United States v. Morgan, 346 U.S. 502 (1954), is a landmark decision[1] by the United States Supreme Court which provides the writ of coram nobis as the proper application to request federal post-conviction judicial review for those who have completed the conviction's incarceration in order to challenge the validity of a federal criminal conviction.

[7] Prior to the Act of June 25, 1948, the writ of habeas corpus was the sole application for United States federal courts to review convictions of those who had completed their incarceration.

Although the Supreme Court states in Carlisle v. United States, “it is difficult to conceive of a situation in a federal criminal case today where [the writ of coram nobis] would be necessary or appropriate [for prisoners and others serving out a term of a federal conviction],”[8] Morgan provides when the writ of coram nobis is necessary or appropriate for those who are no longer in-custody.

In 1939, nineteen-year-old Robert Patrick Morgan pled guilty to stealing three letters from the US Post Office and was sentenced in the United States District Court for the Northern District of New York to four years in federal prison; however, Morgan's constitutional rights were violated because he was not provided an attorney nor did he waive his constitutional right to an attorney.

[9] As a result of his 1939 federal conviction, the county court applied New York's Multiple Offenders Law and sentenced Morgan to seven to ten years at Attica Prison.

On February 5, 1953, the three-judge panel unanimously determined that Morgan was entitled to the writ of coram nobis and reversed the district court's decision.

The source of this controversy is found in footnote 4 of the Morgan decision in which the Court held the writ of coram nobis “is a step in the criminal case” and also “of the same general character as one under 28 U.S.C.