Fontaine v. United States

Defendant was charged with robbery of a federally insured bank. After arraignment, he waived his right to counsel and a grand jury indictment. Before accepting his plea of guilty, Defendant appeared before the judge for a Fed. R. Crim. P. 11 hearing, where the judge addressed him personally to ensure his voluntariness and knowledge of the plea. The judge accepted the plea and sentenced him to 20 years in prison. Two years later, Defendant filed a collateral attack of his conviction under 28 U.S.C. § 2255, alleging that his plea was induced by fear, coercion, and mental illness. As evidence, he attached hospital records from the month following the plea, proving physical abuse, illness, heroin addiction, and other severe mental illnesses. The District Court considered his motion but denied it without an evidentiary hearing, reasoning that all requirements of Fed. R. Crim. P. 11 had been met, so a collateral attack was per se unavailable to Defendant. The Court of Appeals for the Sixth Circuit affirmed. The Supreme Court held that, in this case, an evidentiary hearing was required because the Defendant’s evidence established facts that could warrant relief under § 2255. The Court held that an evidentiary hearing for motions filed under § 2255 is required unless the record and filings “conclusively show” that under no circumstances can the petitioner establish facts that could warrant relief. The Court vacated the judgment of the Court of Appeals and remanded so that the court could hold a hearing on Defendant’s petition.

“It is elementary that a coerced plea is open to collateral attack. It is equally clear that § 2255 calls for a hearing on such allegations unless ‘the motion and the files and records of the case conclusively show that the prisoner is entitled to no relief . . . .'” p.215