Hill v. Lockhart

Defendant pleaded guilty to charges of first-degree murder and theft of property pursuant to a plea agreement. Defendant later filed a federal habeas corpus petition, alleging that his guilty plea was involuntary because he had ineffective assistance of counsel. The Defendant argued that his counsel had given him incorrect information regarding his parole eligibility date. His counsel had told him that if he pleaded guilty he would be eligible for parole after serving one-third of his sentence. However, because the Defendant was a second offender under state law, he was required to serve half of his sentence before he would be eligible for parole. The District Court denied the Defendant’s habeas relief without a hearing. The Court of Appeals of the Eighth Circuit affirmed. The Supreme Court granted certiorari. The Supreme Court held that the two-part Strickland test applies to challenges of guilty pleas based on ineffective assistance of counsel. To satisfy Strickland the Defendant must show that his counsel’s performance was deficient and that the Defendant was prejudiced by such performance. The Court further explained that to meet the prejudice requirement, the Defendant must show that there was a “reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial.” The Court concluded that the Defendant had failed to meet the prejudice requirement under Strickland because he did not allege in his habeas petition that, if he had been correctly informed on his parole eligibility date, he would have not pleaded guilty and insisted on going to trial. Thus, the Court of Appeals judgment was affirmed.

“We believe that requiring a showing of ‘prejudice’ from defendants who seek to challenge the validity of their guilty pleas on the ground of ineffective assistance of counsel will serve the fundamental interest in the finality of guilty pleas we identified in United States v. Timmreck, 441 U.S. 780 (1979).” p.58