rules while other legislatures chose to abolish the names of the writ but provided an alternative remedy under a different name. Tennessee is an example of a state where its legislature enacted a statute expressly authorizing courts to issue, by name, the "Writ of Error Coram Nobis" and regulated how this writ should be issued. In contrast, other states replaced the writ of coram nobis with other post-conviction remedies. For example, the Pennsylvania legislature enacted a law on January 25, 1966, that expressly abolished the name "writ of coram nobis" and enacted the state's Post Conviction Relief Act, which is now the sole means for obtaining post-conviction relief. Coram nobis in United States federal courts In 1789, Congress passed the Judiciary Act to establish the judicial courts in the United States. This Act also allows courts to issue writs, including the writ of coram nobis. Originally, federal courts applied the writ of coram nobis only to correct technical errors, such as those made by a clerk of the court in the records of the proceedings. The 1914 Supreme Court case United States v. Mayer, expanded the scope of the writ of coram nobis to include fundamental errors, but the Court declined in this case to decide whether federal courts are permitted to issue the writ of coram nobis. In 1954, the Supreme Court determined in United States v. Morgan that federal courts are permitted to issue the writ of coram nobis to correct fundamental errors, such as those where discovery of new information is sufficient to prove a convicted felon is actually innocent. Since the Morgan case, federal courts traditionally issue a writ of coram nobis whenever a former federal prisoner petitions the original sentencing court to set aside the conviction based upon new information that was not available when the petitioner was in-custody and where this new information demonstrates that the conviction was a result of a fundamental error. History of the writ of coram nobis in federal courts from 1789 to 1954 The Judiciary Act of 1789 The history of the writ of coram nobis in United States federal courts began in 1789 when Congress enacted the Judiciary Act. Under Section 14 of the Judiciary Act, federal courts have the authority to issue a writ whenever the court deems it necessary to achieve justice and whenever no congressional law covers the issues before the court. This section was