Tollett v. Henderson

Black defendant indicted for first-degree murder pleaded guilty to receive a prison sentence of ninety-nine years. Defendant sought habeas corpus review in both state and federal courts, claiming that his confession to the police had been coerced, he was denied effective assistance of counsel, and he was deprived of his constitutional rights because Black jurors were systematically excluded from grand jury service. The Court denied defendant’s claims, as a defendant is not automatically entitled to collateral relief. A defendant cannot raise independent claims in a federal habeas corpus proceeding. Defendant waived his race claim by raising it years after—instead of before—he pleaded to the indictment. Defendant cannot attack a deprivation of constitutional rights that occurred before he pleaded guilty, but he may attack the voluntary and intelligent nature of his plea by showing that the advice he received from counsel was inadequate. To obtain relief, defendant must demonstrate that the advice was not “within the range of competence demanded of attorneys in criminal cases.”

“When a criminal defendant has solemnly admitted in open court that he is in fact guilty of the offense with which he is charged, he may not thereafter raise independent claims relating to the deprivation of constitutional rights that occurred prior to the entry of the guilty plea.” p.267