to file a coram nobis petition. Currently, this rule only applies to those in the Eighth Circuit Court of Appeals. In 2018, the Eighth Circuit became the first appellate court to decide whether a petition for writ of coram nobis is governed by the Antiterrorism and Effective Death Penalty Act of 1996 ("AEDPA") restrictions on successive relief as defined in § 2255(h)(1) and (2). The Eighth Circuit held that coram nobis petitioners who filed a § 2255 motion, while in custody and the motion was denied while the petitioner remained in custody, is restricted by AEDPA from filing a coram nobis petition without first obtaining authorization from the district court to file the coram nobis petition. This requirement is different from those in custody who are required to obtain authorization from the appellate court in order to file a successive § 2255 motion. Other federal appellate courts have yet to issue an opinion on this question. A petition for a writ of coram nobis must provide adverse consequences which exist from the conviction. A circuit split exists on this requirement. The First, Second, Third, Fifth, Seventh, Eighth, and Tenth circuit courts administer a "civil disabilities test" which requires a coram nobis petitioner to prove that his conviction produced ongoing collateral consequences; however, the Fourth, Ninth and Eleventh Circuits have held that the petitioner need not show that he is suffering from an ongoing "civil disability" because "collateral consequences flow from any criminal conviction". The Sixth circuit has granted coram nobis relief without mentioning this requirement. The writ of coram nobis is an extraordinary remedy to correct errors of the most fundamental character. The error to be corrected must be an error which resulted in a complete miscarriage of justice. In other words, the error is one that has rendered the proceeding itself irregular and invalid. Typically, the same errors that are deemed grounds for Section 2255 habeas relief also justify coram nobis relief. For those claiming actual innocence, a fundamental miscarriage of justice occurs where a constitutional violation has resulted in the conviction of one who is actually innocent. Procedural rules in federal district courts District court clerks should file petitions for writs of coram nobis under the original case number In Morgan, the Supreme Court provided that the writ of coram nobis is a step in the criminal case and not the beginning of a separate civil proceeding. As