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Keywords

defendantattorneyappealhearingtrialpleahabeas corpuswillparoleguilty plea
defendantappealhearingpleaparoleguilty plea

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Hill v. Lockhart, 474 U.S. 52, 106 S.Ct. 366, 88 L.Ed.2d 203, 54 USLW 4006

Facts

William Lloyd Hill pleaded guilty to first-degree murder and theft of property in an Arkansas court, receiving concurrent sentences of 35 years and 10 years, respectively. He later filed a federal habeas corpus petition claiming that his guilty plea was involuntary due to ineffective assistance of counsel, specifically that his attorney misinformed him about his parole eligibility. The District Court denied his petition without a hearing, leading to an appeal that was affirmed by the Court of Appeals.

Pursuant to a plea-bargaining agreement, petitioner pleaded guilty in an Arkansas court to charges of first-degree murder and theft of property, and the court accepted the plea, sentencing him, in accordance with the State's recommendations, to concurrent sentences of 35 years for the murder and 10 years for the theft.

Issue

Did the District Court err in denying the habeas corpus petition without a hearing on the claim of ineffective assistance of counsel related to the guilty plea?

Did the District Court err in declining to hold a hearing on petitioner's claim?

Rule

The two-part Strickland v. Washington test applies to claims of ineffective assistance of counsel, requiring the defendant to show that counsel's performance was deficient and that the deficiency prejudiced the defense.

The two-part standard adopted in Strickland v. Washington, requiring that the defendant show that counsel's representation fell below an objective standard of reasonableness, and that there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different, applies to guilty plea challenges based on ineffective assistance of counsel.

Analysis

The Court applied the Strickland test, determining that Hill's allegations did not satisfy the 'prejudice' requirement. Specifically, Hill failed to demonstrate that, had he been correctly informed about his parole eligibility, he would have chosen to go to trial instead of pleading guilty. The Court noted that the voluntariness of a plea depends on whether the advice given by counsel was within the range of competence expected of attorneys in criminal cases.

In the present case it is unnecessary to determine whether there may be circumstances under which erroneous advice by counsel as to parole eligibility may be deemed constitutionally ineffective assistance of counsel, because petitioner's allegations were insufficient to satisfy the 'prejudice' requirement.

Conclusion

The Supreme Court affirmed the judgment of the Court of Appeals, concluding that the District Court did not err in denying the habeas petition without a hearing.

The judgment of the Court of Appeals is therefore Affirmed.

Who won?

The State prevailed in the case, as the Supreme Court found that the petitioner did not meet the necessary criteria to warrant a hearing on his ineffective assistance of counsel claim.

The District Court did not err in declining to hold a hearing on petitioner's claim.

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