arrives at the same conclusion as other courts of appeals on identical issues raised before those courts. However, whenever the courts of appeals arrive at different conclusions on the same issue, it creates a "circuit split". The Supreme Court receives thousands of petitions each year, but only agrees to hear fewer than 100 of these cases. One of the most compelling reasons for the Supreme Court to accept a case is to resolve a circuit split. Currently, a circuit split exists in coram nobis cases involving the definition of "adverse consequences". The Supreme Court determined in United States v. Morgan that a petition for a writ of coram nobis must demonstrate that adverse consequences exist from the criminal conviction. Some courts of appeals determined adverse consequences occur with any collateral consequence of a conviction while other courts of appeals have limited "adverse consequences" to only a few collateral consequences of a conviction. Federal district court decisions District courts must abide by congressional statutes, Supreme Court decisions, and decisions of the court of appeals in the federal judicial circuit in which the district court is located. Whenever a district court hears an issue that is not specifically addressed by statute or by case law of a higher court, district courts often "develop the record". In case of an appeal, the higher courts have the district court's reasoned decision as guidance. A developed record not only greatly facilitates the process of appellate review but also ensures that the district court has carefully considered the issues and applied the applicable law. Criteria for the writ Rules for petitioners Writs of coram nobis are rare in U.S. federal courts due to the stringent criteria for issuance of the writ. Morgan established the following criteria required in a coram nobis petition in order for a federal court to issue the writ: A petition for a writ of coram nobis is a collateral attack on a judgment in a federal criminal case. A "collateral attack" is defined as an attack on a judgment in a proceeding other than a direct appeal. A petition for a writ of coram nobis in a federal court must seek to vacate a federal criminal conviction. A writ of coram nobis is not available in federal courts to challenge a conviction in a state court. The federal government operates its own coram nobis procedures independent from state courts. Those seeking to