Rawlins v. State of Kansas, 2013 U.S. App. LEXIS 8727

Rawlins was convicted in Kansas state court in 2001 for battery of a police officer and received a 12-month suspended sentence and 3 years' probation.
After exhausting direct and post-conviction state remedies through 2011, Rawlins was no longer in custody, so § 2254 habeas relief became unavailable due to the 'in custody' requirement.
Rawlins sought audita querela or coram vobis in federal district court to reargue constitutional claims; the district court assumed audita querela and denied relief.
The court concluded the writs were improper and assessed Rawlins’s claims as if under § 2254, but denied relief on the merits.
The court held coram nobis is the proper analogue writ, but federal courts lack jurisdiction to review state-court judgments via coram nobis, so relief could not be granted.
On appeal, the Tenth Circuit vacated and remanded to dismiss for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper writ to review post‑custody state judgment	Rawlins urged coram nobis/coram vobis or audita querela as vehicle to challenge state judgment.	District court initially treated as audita querela and rejected merits; coram nobis jurisdictional limits apply.	Coram nobis is the proper analogue writ, but federal courts cannot review state judgments via coram nobis.
Whether audita querela is available to post-judgment relief	Audita querela could address post-judgment circumstances and permit relief.	Audita querela is not appropriate here and has limited use, particularly in immigration contexts; it does not fit.	Audita querela is not a viable path for reviewing Rawlins's state conviction in federal court.
Authority to review a state judgment in federal court	Rawlins seeks federal relief despite not being in custody under state judgment.	Federal courts lack power to review state judgments via coram nobis or similar writs.	Federal courts have no jurisdiction to review state-court judgments through coram nobis.

United States v. Morgan, 346 U.S. 502 (1954) (coram nobis available in limited extraordinary criminal contexts)
Maleng v. Cook, 490 U.S. 488 (1989) (in custody requirement not satisfied after sentence ends)
Oliver v. City of Shattuck ex rel. Versluis, 157 F.2d 150 (10th Cir. 1946) (audita querela historical basis in habeas context)
United States v. Hayman, 342 U.S. 205 (1952) (utilizes common-law writs; guides auxiliary writs analysis)
Davis v. Roberts, 425 F.3d 830 (10th Cir. 2005) (limits coram nobis to traditional jurisdictional scope)
Morgan v. United States, none (see Morgan) (see above; included for context on coram nobis scope)