UNITED STATES OF AMERICA v. SHIRLEY DOUGLAS (2025)

ORDER DENYING MOTION FOR WRIT OF ERROR CORAM NOBIS

Defendant Shirley Douglas pleaded guilty on September 18, 2019 to conspiring to distribute controlled substances. On December 3, 2019, the Court sentenced her to 132 months in prison. Douglas appealed, and the Sixth Circuit affirmed the conviction and sentence on February 23, 2021. In 2021, she filed a motion to vacate her conviction and sentence under 28 U.S.C. § 2255, which was denied by the Court in an opinion issued on July 26, 2024. Douglas filed several other post-conviction motions seeking compassionate release and sentence reductions, all of which were denied. On October 22, 2025, Douglas filed a “motion for writ of error coram nobis,” in which she asks the Court to vacate her conviction and sentence on the grounds that her guilty plea was involuntary and she was coerced to plead guilty due to “prosecutorial overreach.”

The motion will be denied because a writ of error coram nobis is not a vehicle for mounting cumulative collateral attacks on a criminal conviction and sentence. Generally such a challenge must come through a motion filed under 28 U.S.C. § 2255. United States v. Hallom, 505 F. App'x 480, 481-82 (6th Cir. 2012) (“Several circuits, in addition to this one, have held that § 2255 is the exclusive remedy for individuals seeking to collaterally challenge the validity of a sentence.”). Moreover, Douglas previously filed a motion to vacate under section 2255 which was denied, and the denial was affirmed on appeal. The issues raised in the instant petition could have been presented on direct appeal, or in the previously adjudicated motion to vacate. “A coram nobis petition is not a means to relitigate issues that have already been decided or could have been raised in [the petitioner's] § 2255 proceedings.” Brown v. United States, No. 23-5158, 2023 WL 11818993, at *2 (6th Cir. Nov. 27, 2023) (collecting cases); see also Pilla v. United States, 668 F.3d 368, 372 (6th Cir. 2012) (“If, in substance, a claim falls within the scope of [28 U.S.C.] § 2255(a), it should be treated as such regardless of any ‘inventive captioning’ by the prisoner.”); Melton v. United States, 359 F.3d 855, 857 (7th Cir. 2004) (“Any motion filed in the district court that imposed the sentence, and substantively within the scope of § 2255, is a motion under § 2255, no matter what title the prisoner plasters on the cover. Call it a motion for a new trial, arrest of judgment, mandamus, prohibition, coram nobis, coram vobis, audita querela, certiorari, capias, habeas corpus, ejectment, quare impedit, bill of review, writ of error, or an application for a Get-Out-of-Jail Card; the name makes no difference. It is substance that controls.”). The present motion seeks relief that may not be obtained through a writ of coram nobis, and the motion therefore must be denied.

Accordingly, it is ORDERED that the motion for a writ of error coram nobis (ECF No. 480) is DENIED.

DAVID M. LAWSON United States District Judge