Coram Nobis Relief Limits Following Van Buren: Partial CFAA Vacatur and Persistent Felon Status

Introduction

In Charles Daniel Maye v. United States, No. 24-10239 (11th Cir. Jan. 31, 2025), the Eleventh Circuit addressed whether a federal prisoner who served his sentence could use the writ of error coram nobis to vacate portions of his convictions invalidated by Van Buren v. United States. The petitioner, Charles Maye—a former sheriff’s deputy convicted in 2006 of computer‐fraud conspiracy (18 U.S.C. § 371), unauthorized database access under the Computer Fraud and Abuse Act (CFAA, 18 U.S.C. § 1030(a)(2)(B)), and making false statements to federal agents (18 U.S.C. § 1001(a)(2))—had already completed his prison term, supervised release, and paid a fine. Relying on Van Buren (593 U.S. 374 (2021)), which narrowed the CFAA “exceeds authorized access” clause, Maye sought coram nobis relief to vacate his CFAA convictions for accessing law-enforcement databases for a private purpose. The government conceded those counts were invalid under Van Buren but opposed relief on his remaining false‐statement and conspiracy convictions. The district court denied relief, and the Eleventh Circuit affirmed.

Summary of the Judgment

The court held that under Van Buren Maye’s CFAA convictions (Counts Two and Four) were invalid because he accessed databases he was authorized to use for improper purposes, not for unauthorized areas of a computer.
Maye’s conspiracy conviction (Count One) built in part on CFAA violations and thus was arguably infirm, but the false‐statement conviction (Count Five) remained valid because Van Buren did not affect 18 U.S.C. § 1001(a)(2).
The Eleventh Circuit reaffirmed that coram nobis is an extraordinary remedy available only when no other relief exists and a fundamental jurisdictional error occurred.
Vacating only the CFAA‐based convictions would leave Maye’s felon status—and all attendant collateral consequences—intact due to his valid false‐statement conviction.
Because Maye’s continuing disabilities (loss of pension, firearm rights, reputation, employment and travel restrictions) stemmed from his status as a felon, not any specific count, coram nobis relief was properly denied.

Analysis

Precedents Cited

Van Buren v. United States, 593 U.S. 374 (2021) – Narrowed CFAA § 1030(a)(2)(B) to prohibit accessing computer areas off-limits to a user, not using authorized access for improper ends.
United States v. Peter, 310 F.3d 709 (11th Cir. 2002) – Confirmed that coram nobis can correct subject-matter jurisdiction errors when conduct does not constitute a federal offense.
Alikhani v. United States, 200 F.3d 732 (11th Cir. 2000) – Sets the high bar for coram nobis: no other remedy available, fundamental factual error, irregular and invalid proceeding.
Mills, 221 F.3d 1201 (11th Cir. 2000) – Described coram nobis as “extraordinary relief of last resort.”
Rener v. United States, 475 F.2d 125 (5th Cir. 1973), Rodgers v. United States, 451 F.2d 562 (5th Cir. 1971), and Campbell v. United States, 538 F.2d 692 (5th Cir. 1976) – Held that coram nobis is inappropriate where vacating part of the conviction does not alleviate collateral consequences of felon status.

Legal Reasoning

The court applied a two-step analysis for coram nobis:

Jurisdictional Error? Maye’s CFAA convictions were invalid post‐Van Buren, but his false‐statement conviction under 18 U.S.C. § 1001(a)(2) remained valid, as Van Buren did not address § 1001.
Relief Necessary to Remedy Collateral Consequences? Even if Counts Two, Four, and potentially One were vacated, Count Five ensured Maye’s continued status as a felon. The harms he described—retirement benefit loss, firearm disqualification, stigma, employment and travel restrictions—flowed from that felon status, not from any specific invalidated count.

Because vacatur of only the CFAA convictions would not remove those burdens, Maye failed to show the “compelling circumstances” required for coram nobis. Granting partial relief would be a “futile decree” under binding precedent.

Impact

This decision clarifies limits on coram nobis in two respects:

Scope of Van Buren Effects: Invalid CFAA convictions do not automatically invalidate related conspiracy counts unless they alone supply federal jurisdiction and exhaust all bases for conspiracy liability.
Coram Nobis Relief Requires Full Remedy: Petitioners must demonstrate that vacating judgments will actually restore neglected rights or eliminate collateral consequences. Partial vacatur is insufficient if remaining convictions sustain felon disabilities.

Future litigants should recognize that coram nobis is not a tool for piecemeal relief when any valid conviction persists.

Complex Concepts Simplified

Writ of Error Coram Nobis: A post-sentencing remedy under the All Writs Act for people out of custody who claim a fundamental error (like lack of jurisdiction) left no adequate chance to challenge the conviction.
“Exceeds Authorized Access” (CFAA): After Van Buren, liability exists only if a user accesses parts of a computer off-limits to him, not simply if he misuses data he is allowed to see.
Collateral Consequences: Disabilities or disadvantages (e.g., loss of civil rights, social stigma, professional licensing problems) that flow from being a felon, separate from actual punishment.

Conclusion

Charles Daniel Maye v. United States confirms that coram nobis is a narrow remedy reserved for cases where an absolute jurisdictional defect left a conviction void and no other relief remains. Even though Van Buren eliminated some CFAA convictions, Maye’s unwavering false-statement conviction preserved his felon status and all attendant disabilities. Partial vacatur, without full restoration of rights, fails the “compelling circumstances” test. This ruling underscores that litigants seeking coram nobis must secure relief sufficient to cure the practical harms of their convictions, not just theoretical errors in part of their sentences.