reviewed all relief previously provided for civil cases through the writ of coram nobis and adopted those avenues of relief into the rules; therefore, eliminating the need for the writ in federal civil cases. In the amendment, Congress expressly abolished the writ of coram nobis in Rule 60(b). Later, in 2007, Congress restructured the format of Rule 60, and moved the language expressly abolishing the writ of coram nobis in civil proceedings from Rule 60(b) to Rule 60(e) in the Federal Rules of Civil Procedure. History of post-conviction remedies available to former federal prisoners from 1789 to 1954 Post-conviction remedies for former federal prisoners prior to 1867 In 1790, one year after Congress passed the Judiciary Act establishing federal courts, Congress enacted the Crimes Act which created the first comprehensive list of federal offenses. From 1790 until 1867, there are few, if any, records of individuals challenging a federal criminal conviction after completion of the prison sentence. Two primary reasons explain the absence of any challenges to a conviction by former federal prisoners: The Crimes List provided only twenty-three federal crimes. Seven of these crimes, including treason and murder, were punishable by death. (In comparison, today there are approximately 3,600 to 4,500 federal statutes that impose criminal punishments.) There are an estimated 500,000 former federal prisoners. Despite this large population, recent cases where a former federal prisoner is able to find new information sufficient to reverse the conviction are exceedingly rare. Thus, the chances of this type of case arising prior to 1867, when the federal prison population was significantly smaller, are even more remote. There were few collateral consequences stemming from a conviction at this time. Generally, the reason former convicted felons seek a writ of coram nobis is to eliminate collateral consequences ensuing the challenged conviction. Collateral consequences are indirect consequences of a conviction. While direct consequences of a conviction are usually issued by a judge in the sentencing phase of a case (such as a prison sentence, probation, fines and restitution); indirect consequences of a conviction are not contained within a court sentence. Collateral consequences may include loss of voting privileges, loss of professional licenses, inability to qualify for some employment and housing opportunities, and damage to the person's reputation. The Habeas Corpus Act of 1867 The American Civil War is historically significant upon the rights of former federal prisoners in two ways. First, Congress enacted the