United States v. Luther Woods

── United States v. Luther Woods ── Court: Court of Appeals for the Eleventh Circuit Date: June 02, 2026 Category: NEW USCA11 Case: 25-13542 Document: 25-1 Date Filed: 06/02/2026 Page: 1 of 3 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-13542 Non-Argument Calendar ____________________ UNITED STATES OF AMERICA, Plaintiff-Appellee, versus LUTHER WOODS, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Middle District of Florida D.C. Docket No. 6:94-cr-00166-RBD-KRS-1 ____________________ Before ROSENBAUM, GRANT, and BLACK, Circuit Judges. PER CURIAM: Luther Woods, a former federal prisoner and current Florida state prisoner proceeding pro se, appeals the district court’s denial of his petition for a writ of error coram nobis. Woods contends he USCA11 Case: 25-13542 Document: 25-1 Date Filed: 06/02/2026 Page: 2 of 3 2 Opinion of the Court 25-13542 is entitled to coram nobis relief because the statute he was con- victed of violating in 1994, 28 U.S.C. § 2113(d), is unconstitutional and his indictment was defective. 1 The Government has moved for summary affirmance of the district court’s order. After review, 2 we affirm. The All Writs Act, 28 U.S.C. § 1651, gives federal courts au- thority to issue writs of error coram nobis. United States v. Mills, 221 F.3d 1201, 1203 (11th Cir. 2000). The writ, however, may issue only when (1) “there is and was no other available avenue of relief,” and (2) “the error involves a matter of fact of the most fundamental character which has not been put in issue or passed upon and which renders the proceeding itself irregular and invalid.” Alikhani v. United States, 200 F.3d 732, 734 (11th Cir. 2000) (emphasis added) (quotation marks omitted)). Moreover, a petitioner must show “sound reasons” for not raising claims “at the earliest opportunity.” Gonzalez v. United States, 981 F.3d 845, 852 (11th Cir. 2020) (quota- tion marks omitted). Procedural ignorance is not a sound excuse for a delay in raising claims in a coram nobis petition. Id. at 853. 1 In his writ of error coram nobis, Woods also claimed he received ineffective assistance of counsel, but does not brief this issue on appeal. Thus, he has abandoned this argument. See Timson v. Sampson, 518 F.3d 870, 874 (11th Cir. 2008) (stating an issue is abandoned on appeal if a pro se litigant does not brief it). 2 We review a district court’s denial of a petition for writ of error coram nobis for an abuse of discretion. Alikhani v. United States, 200 F.3d 732, 734 (11th Cir. 2000). USCA11 Case: 25-13542 Document: 25-1 Date Filed: 06/02/2026 Page: 3 of 3 25-13542 Opinion of the Court 3 The district court did not abuse its discretion in denying co- ram nobis relief because Woods failed to present a sound reason for failing to raise his challenges to § 2113(d) and the indictment at any earlier stage in the proceedings. See Gonzalez, 981 F.3d at 852. Rather, Woods’ only asserted reason was that he was unaware of the errors until May 2025. This reason fails, first, because it is an argument from procedural ignor