(104) In equity, judges similarly retained power to modify a decree until it was "enrolled"; thereafter, a petitioner would need to request a bill of review. (165)
(171) But in 1938, the Federal Rules of Civil Procedure nominally merged law and equity, subsuming the legal writ of error coram nobis and the equitable bill of review into a single "motion for relief from judgment." (172) Nevertheless, the merger did not rob history of its significance.
No decree shall be reversed, altered, or explained, being once under the great seal, but upon bill of review: and no bill of review shall be admitted, except it contain either [(1)] error in law, appearing in the body of the decree without farther examination of matters in fact, or [(2)] some new matter which hath risen in time after the decree, and not any new proof which might have been used when the decree was made: nevertheless [(3)] upon new proof, that is come to light after the decree made, and could not possibly have been used at the time when the decree passed, a bill of review may be grounded by the special license of the court, and not otherwise.