In Skok v. State, 361 Md. 52, 65, 760 A.2d 647 (2000), the appellant was a U.S. permanent resident who served a few days in jail in connection with his guilty plea and his plea of nolo contendere as to two drug possession offenses. Despite the relatively minor nature of the offenses, Skok subsequently faced deportation proceedings because the convictions constituted immigration violations. Consequently, Skok filed, inter alia, a coram nobis petition, seeking to vacate his 1994 judgments of conviction. He argued, in relevant part, that his pleas were defective because the circuit court failed to comply with the requirements of Maryland Rule 4-242(c) and (d). In particular, he claimed that the court violated Rule 4-242(c) because the court did not require that the facts supporting the plea be read in open court in the defendant's presence, did not expressly find on the record that the factual basis supported a finding of guilty, did not advise Skok of the possible consequences of his plea, and did not properly advise Skok of his right to a jury trial. Skok claimed that the Circuit Court, in accepting his nolo contendere plea in October 1994, violated Rule 4-242(d) because there was no examination of Skok in open court for a determination that the plea was made voluntarily, with an understanding of the nature of the charge and the consequences of the plea. Skok also contended that due process principles were violated because both pleas were involuntary, that they were not knowingly and intelligently made, and that there was no valid waiver of his rights, including his right to jury trials. Id. at 57-58. The circuit court denied Skok's request for coram nobis relief; the Court of Appeals reversed. The Court of Appeals acknowledged that "the scope of the issues which could be raised in a traditional coram nobis proceeding" is "narrow." Id. at 68. Of particular interest here, the Court also made clear that, traditionally, "one of the issues which could be raised in a coram nobis proceeding was the voluntariness of a plea in a criminal case." Id. The Court explained, 361 Md. at 80-81: The courts have consistently held that the scope of a coram nobis proceeding encompasses issues concerning the voluntariness of a guilty or nolo contendere plea, and whether the record shows that such plea was understandingly and voluntarily made under the principles of Boykin v. Alabama, supra, 395 U.S. 238, 89 S. Ct. 1709, 23 L. Ed. 2d 274. Moreover, the courts have regularly held that violations of rules similar to Maryland Rule 4-242, which are designed to insure that guilty and nolo contendere pleas are voluntary, constitute a basis for coram nobis relief. In the Skok Court's view, "sound public policy" warranted a "somewhat broader scope of coram nobis." Id. at 70. The Court noted intervening changes in immigration law and the enactment of recidivist statutes, with attendant collateral consequences, as a basis to broaden coram nobis relief. Id. at 77-78. It reasoned: "'The present-day scope of coram nobis is broad enough to encompass not only errors of fact that affect the validity or regularity of legal proceedings, but also legal errors of a constitutional or fundamental proportion.'" Id. at 75 . The Court said, at 361 Md. at 78: In light of these serious collateral consequences, there should be a remedy for a convicted person who is not incarcerated and not on parole or probation, who is suddenly faced with a significant collateral consequence of his or her conviction, and who can legitimately challenge the conviction on constitutional or fundamental grounds. Such person should be able to file a motion for coram nobis relief regardless of whether the alleged infirmity in the conviction is considered an error of fact or an error of law. The Court in Skok recognized that a plea taken in violation of constitutional principles or in violation of Rule 4-242(c) and (d) may fail "to ascertain from the accused the requisite answers, information or facts permitting the court to determine that a guilty plea . . . is voluntary." That would result in "an erroneous factual gap, relating to a voluntariness matter which is not adjudicated by the court on a complete factual record. . . ." Id. at 70. It cautioned, however, that important limitations apply to coram nobis when it serves as a basis to challenge criminal convictions. Id. at 78. First, the challenge must be of a "constitutional, jurisdictional or fundamental character." Id. at 78. Second, the petitioner must face "significant collateral consequences from the conviction." Id. at 79. Moreover, because a presumption of regularity attaches to the criminal case, the burden of proof is on the coram nobis petitioner. Id. at 78. But, coram nobis is not available when another remedy is applicable under statutory or common law. Id. at 80. Further, the principles of waiver apply to coram nobis actions. Id. at 79. Significantly, the issues regarding the validity of Skok's plea were not litigated, although Skok faced "substantial collateral consequences from his two convictions," id. at 82, and he lacked any other remedy. Therefore, the Court determined that he was entitled to a hearing on his petition seeking coram nobis relief. Id. The Court of Appeals expanded the scope of coram nobis relief to include errors of law, stating that a person who meets the requirements for coram nobis relief "should be able to file a motion for coram nobis relief regardless of whether the alleged infirmity in the conviction is considered an error of fact or an error of law." Id. at 78 Although the Skok decision served to broaden the scope for relief, the Court emphasized that such relief is "subject to several important qualifications." Id. Particularly, in order for a petitioner to obtain coram nobis relief, whether on the basis of error of fact or error of law, the burden of proof is on the petitioner to show that the grounds for challenging the criminal conviction are of a constitutional, jurisdictional, or fundamental character; that the petitioner is suffering or facing significant collateral consequences from the conviction; and that there is no other statutory or common law remedy then available. Id. at 78-80. Additionally, one is not entitled to challenge a criminal conviction in a coram nobis proceeding when an issue has been finally litigated in a prior proceeding, and there are no intervening changes in the applicable law or controlling case law. Id. at 80. In sum, the Court of Appeals expanded the traditional scope of coram nobis relief in Maryland, but did so "subject to several important qualifications." Id. at 78. Those qualifications are that the grounds for challenging a criminal conviction "must be of a constitutional, jurisdictional or fundamental character" id.; that "the burden of proof is on the coram nobis petitioner" id.; that "the coram nobis petitioner must be suffering or facing significant collateral consequences from the conviction," id. at 79; that "basic principles of waiver are applicable", id. and that "one is not entitled to challenge a criminal conviction by a coram nobis proceeding if another statutory or common law remedy is then available." Id. at 80 .