abolish the writ of coram nobis in federal civil cases. Prior to enacting this statute, Congress reviewed all issues previously addressed by federal courts in writ of coram nobis proceedings, and incorporated remedies for those issues within the procedures. Rule 60(e) of this Procedure originated from this statute and states, "The following are abolished: bills of review, bills in the nature of bills of review, and writs of coram nobis, coram vobis, and audita querela." In 2002, Congress enacted Rule 4(a)(1)(C) of the Federal Rules of Appellate Procedure to resolve a conflict among the federal appellate courts regarding the time limitations to file an appeal from an order granting or denying an application for a writ of error coram nobis. Prior to this amendment, the federal appellate courts were divided on whether coram nobis appeals have a 10-day time limit or a 60-day time limit. Rule 4(a)(1)(C) resolved the conflict and established a 60-day time limit to file the notice of appeal from a district court's judgement in a coram nobis proceeding. United States Supreme Court decisions Following the Constitution and Congressional statutes, the next highest source for direction and guidance of rules and procedures is the United States Supreme Court. The Supreme Court is the highest federal court. Lower courts, such as federal appellate courts and federal district courts, must follow the decisions of the Supreme Court. The Supreme Court has discretionary appellate jurisdiction, meaning the Court chooses to hear cases for reasons it deems "compelling reasons" (such as resolving a conflict in the interpretation of a federal law or resolving an important matter of law). Federal courts, including the Supreme Court, cannot override any law enacted by Congress unless the law violates the Constitution. Federal courts also cannot repeal a statute unless Congress clearly intended to repeal the statute. In 1954, United States v. Morgan provides writ of coram nobis to former federal prisoners. The Court determined coram nobis relief "should be allowed ... only under circumstances compelling such action to achieve justice". Specifically, the circumstances must include all three of these conditions: to remedy errors "of the most fundamental character" when "no other remedy [is] then available" "sound reasons [exist] for failure to seek appropriate earlier relief". Since 1954, the Supreme Court granted review of only one other coram nobis case. In 2009, the Court clarified that Article I military courts have jurisdiction to entertain coram nobis