known as the "All-Writs Provision" of the Judiciary Act until 1948 when it became more commonly known as the "All-Writs Act" after Congress modified the Judicial Code and consolidated this provision into . Under the All Writs Act, federal district courts have the "power to issue writs of scire facias, habeas corpus, and all other writs not specifically provided for by statute". Congress had not specifically provided by statute the authority for federal courts to issue a writ of coram nobis; therefore, the All Writs Act provides federal courts this authority. The first case in a federal court to address the writ of coram nobis was Strode v. The Stafford Justices in 1810. In this case, the Supreme Court Chief Justice John Marshall wrote the opinion in this Circuit Court case and held that the writ of coram nobis is distinguishable from the writ of error and therefore not subject to the writ of error's statute of limitations. The first Supreme Court case mentioning the writ of coram nobis (using the term coram vobis) is the 1833 case, Pickett's Heirs v. Legerwood. In this case, the Court determined that the writ was available to correct its own errors, but the same remedy was also available using the preferred method of submitting a motion to the court. Eighty years later, in 1914, the Supreme Court reached a similar conclusion in United States v. Mayer. Thus, while federal courts confirmed the writ of coram nobis was available to federal courts, this remedy was rarely necessary or appropriate in federal courts throughout the nineteenth century for the following two reasons: Courts generally considered the writ of coram nobis to be restricted to correct only technical errors, such as discovery of a defendant being under age, evidence that a defendant died before the verdict, or errors made by the court clerk in the recording of the proceedings. Petitioners could raise a "motion to amend" to correct most of errors also corrected by the writ of coram nobis. Although courts recognized that the writ of coram nobis could also reverse the judgement on such defects, the preferred practice was to present the court with a motion to amend. 1946 amendments to the Rules of Civil Procedure In 1946, Congress amended the Federal Rules of Civil Procedure and specifically abolished the writ of coram nobis in federal civil cases. Prior to enactment of these amendments, Congress