or she is detained". In 1885, the Supreme Court read these application requirements as an intent by Congress to restrict the writ of habeas corpus to only those who were physically restrained in jail. Thus, the Court foreclosed the writ of habeas corpus to those no longer in custody. United States v. Morgan (1954) provides writ of coram nobis to former federal prisoners In 1948, Congress passed legislation that would lead to the official recognition of the writ of coram nobis in federal courts. The Act of June 25, 1948 combined two pieces of legislation: Congress passed the Act to organize all laws of the United States into a single source of reference, known as the United States Code (abbreviated U.S.C.). Any law (or statute) ever passed by Congress can be found in the United States Code. The U.S.C. is divided into 50 titles. Within each title is a chapter, and within each chapter is a section. For example, one of the titles created in the Act was Title 28 – Judiciary and Judicial Procedure. Chapter 153 of this title is the chapter on Habeas Corpus. Section 2255 of this title is the section providing how prisoners can challenge a conviction. In legal documents, this section is commonly abbreviated 28 U.S.C. §2255. Congress passed the Act to solve a problem with habeas corpus petitions. The Habeas Corpus Act of 1867 instructed prisoners to file a writ of habeas corpus with the district court whose territory included the prison. For example, those imprisoned at Alcatraz Island, California were required to file a writ of habeas corpus in the United States District Court for the Northern District of California, even if the prisoner's conviction and sentence originated from a federal court in another district or state. This rule led to administrative difficulties, especially for the five district courts whose territorial jurisdiction included major federal prisons. The Act of June 25, 1948 codified existing federal habeas corpus statutes and judicial habeas practice at 28 U.S.C. §2255 and changed the jurisdiction from the district of confinement to the district of sentence; however, the jurisdictional change was the only change Congress intended. The Act of June 25, 1948 reworded the habeas corpus sections of the United States Code to provide only those individuals in-custody (as a result of a criminal conviction in federal court) access to the writ of habeas corpus. For those who had