US v. Antonio McDaniel, No. 20-7579 (4th Cir. 2023)
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Defendant sought post-conviction relief under 28 U.S.C. Section 2255 and, in the alternative, coram nobis relief. His Section 2255 motion and his coram nobis petition were both denied by the district court. In this appeal, Defendant challenged only the denial of his petition for coram nobis relief, asserting that the court erred and abused its discretion in so ruling. Defendant maintains that he is entitled to a writ of coram nobis because (1) he was convicted in that very court in 1993 under 18 U.S.C. Section 924(c), (2) he has served his sentence for that offense, and (3) the sole predicate for his 1993 conviction — a violation of 18 U.S.C. Section 111 — is no longer a crime of violence.
The Fourth Circuit affirmed. The court explained that the two issues involve (1) whether a violation of Section 111(b) constitutes a crime of violence and (2) whether Defendant has shown that his 1993 conviction does not rest on a Section 111(b) violation. The court wrote that an error of the most fundamental character has not been shown, Defendant is not entitled to a writ of coram nobis, and the district court did not abuse its discretion in denying coram nobis relief. The court explained that Defendant was obliged to show that his 1993 conviction rested solely on Section 111(a). Defendant has not carried that burden, and he therefore has not satisfied the fourth requirement for coram nobis relief.
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