The Sixth Circuit violated Mr. Brown's due process rights by concluding that his right to file a coram nobis petition fell within the scope of his appeal waiver and that he was barred from filing his petition.

The Sixth Circuit erred by holding that Mr. Brown's petition did not fall with the miscarriage of justice exception.

It is of enormous importance to the bar and the judiciary for this court to answer whether a waiver entered by a defendant contemporaneously with a guilty plea, absent explicit language, includes the defendant's right to file a coram nobis petition following full service of his sentence.

Whether a defendant's appeal waiver bars the filing of a coram nobis petition following full service of his sentence