McMann v. Richardson

This opinion consolidates the cases of three unrelated defendants who pleaded guilty after allegedly being coerced to confess to their respective offenses. Dash, Richardson, and Williams were all threatened and beaten. Dash alleged his trial judge threatened false charges, and Richardson and Williams alleged ineffective assistance of counsel. All petitioned for writs of habeas corpus, which the district courts denied. Although the Court of Appeals for the Second Circuit reversed in each case, the Supreme Court upheld the district courts’ denial. The Court held that defendants who allege their coerced confessions induced their guilty pleas are not entitled to a hearing on petitions for habeas corpus without a greater showing. In its ruling, the Court made the unsupported assumption that a defendant who considers their confession involuntary and thus unusable against them would not plead guilty, but instead would contest their guilt at trial. The Court also surmised that defendants who believed their confessions were admissible at trial were more likely to plead guilty. The Court went on to state that a defendant cannot blame their plea on the confession, for each is a distinct act. A plea that is voluntary and intelligent may still be valid even if the defendant later decides his confession is coerced and inadmissible. The plea can only be collaterally attacked on grounds of coerced confession if the defendant was incompetently advised by their attorney. The Court distinguishes the three defendants—who were convicted on their counseled admission in open court—from the accused whose conviction after trial rests upon a coerced confession. The defendants are not entitled to collateral review when otherwise-competent counsel has misjudged the state of their confession.

“Nothing in this train of events suggests that the defendant’s plea, as distinguished from his confession, is an involuntary act. His later petition for collateral relief asserting that a coerced confession induced his plea is at most a claim that the admissibility of his confession was mistakenly assessed and that since he was erroneously advised, either under the then applicable law or under the law later announced, his plea was an unintelligent and voidable act. The Constitution, however, does not render pleas of guilty so vulnerable.” p.769