a result, district courts, such as those in the Ninth Circuit, file petitions for writs of coram nobis under the original criminal case number. District courts should construe incorrectly titled petitions with the appropriate title. Whenever a federal district court receives an incorrectly labeled or incorrectly titled petition, the court should construe the petition correctly. District courts should construe a coram nobis petition from a federal prisoner as a petition for writ of habeas corpus. Similarly, district courts should construe a habeas corpus petition from a former federal prisoner as a petition for writ of coram nobis. Federal courts have determined that a person on probation is still a federal prisoner; therefore, petitioners in this category must file a petition for writ of habeas corpus. A federal prisoner convicted of more than one federal crime may file a petition for writ of coram nobis to challenge any conviction where the sentence is complete; but the prisoner must file a writ of habeas corpus to challenge any conviction where the sentence is not complete. Procedural rules in federal appellate courts Appeals from coram nobis orders are subject to a 60-day filing period. Until 2002, two provisions in Morgan divided the federal appellate courts interpretation on the time limits to file an appeal from a district court's decision on a coram nobis petition. First, Morgan held that "the writ of coram nobis is a step in the criminal case". Second, Morgan held that "the writ of coram nobis is of the same general character as the writ of habeas corpus". This created a conflict in the courts of appeals regarding the time limits that applied to appeals from coram nobis orders. In 2002, Congress added language to the Federal Rules of Appellate Procedure that clarified an application for a writ of error coram nobis is subject to a 60-day filing period. Appeals from coram nobis orders do not require a certificate of appealability. In 1996, Congress enacted the Antiterrorism and Effective Death Penalty Act of 1996 ("AEDPA") which included language that limits the power of federal judges to grant motions for habeas relief, including motions for relief pursuant to 28 U.S.C. § 2255. AEDPA requires a Certificate of Appealability in order to appeal a district court's ruling on a habeas corpus petition. Unlike the writ of habeas corpus, a Certificate of Appealability is not required in order to appeal a district court's