State v. David J. Widi, Jr., 166 A.3d 1105

In 2004 Widi pleaded guilty to reckless conduct; sentencing documents and mittimus recorded a felony conviction though he initially intended a misdemeanor plea negotiation.
In 2008 Widi discovered his 2004 conviction was recorded as a felony and was later convicted in federal court in 2012 of being a felon in possession of a firearm, relying on the 2004 conviction as the predicate felony.
In 2010 Widi filed a Motion to Correct the Record to reclassify the 2004 conviction as a misdemeanor; the trial court denied it and Widi’s requests for discretionary review were refused (including cert. denial).
In November 2014 Widi filed a petition for a writ of coram nobis alleging misclassification of the conviction, actual innocence of the felony, involuntary plea, and ineffective assistance of counsel; the trial court denied the petition without an evidentiary hearing.
The Supreme Court of New Hampshire addressed whether a trial court may deny a coram nobis petition without an evidentiary hearing and whether Widi’s unexplained delay barred relief.

Issue	Widi's Argument	State's Argument	Held
Whether coram nobis petition must trigger an evidentiary hearing	Court should assume petition facts true and grant hearing to prove claims	No absolute right to hearing; hearing unnecessary if record shows petition lacks merit	A hearing is not required if the record clearly shows petitioner not entitled to relief
Whether coram nobis is available and standard for delay	Assumes claims cognizable in coram nobis	Agrees coram nobis exists but stresses threshold of sound reasons for delay	Coram nobis remains available; petitioner must show sound reasons for failing to seek earlier relief
Whether Widi’s claims were barred by delay and previous proceedings	Delay excused because he only discovered felony classification in 2008 and pursued relief thereafter	Widi failed to explain six-year lapse (2008–2014) and raised claims already presented in 2010 motion	Petition denied: Widi did not show sound reasons for delay and reasserted previously rejected claims
Whether the record compelled relief on the merits	Widi argued alleged errors (misclassification, involuntary plea, ineffective assistance) merited relief and hearing	Record itself refuted claims or showed they were not new; no basis for relief without new facts	Court found record demonstrated no entitlement to coram nobis; denial without hearing was proper

Lamb v. Shaker Reg’l Sch. Dist., 168 N.H. 47 (discussing civil pleading standards and inference-drawing)
Grote v. Powell, Commissioner, 132 N.H. 96 (a habeas petition may be denied without an evidentiary hearing when the record conclusively shows no entitlement to relief)
United States v. Michaud, 925 F.2d 37 (1st Cir.) (conclusory coram nobis allegations unsupported by specifics do not require an evidentiary hearing)
United States v. Morgan, 346 U.S. 502 (establishing coram nobis as a post-conviction remedy for errors of the most fundamental character)
Owensby v. United States, 353 F.2d 412 (10th Cir.) (no hearing required where petition on its face shows petitioner not entitled to relief)