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Hill v. Lockhart - 474 U.S. 52, 106 S. Ct. 366 (1985)

Rule:

The two-part Strickland test applies to challenges to guilty pleas based on ineffective assistance of counsel. In the context of guilty pleas, the first half of the test is nothing more than a restatement of the standard of attorney competence. The second, or "prejudice," requirement, on the other hand, focuses on whether counsel's constitutionally ineffective performance affected the outcome of the plea process. In other words, in order to satisfy the "prejudice" requirement, the defendant must show that there is a reasonable probability that, but for counsel's errors, he would not have pleaded guilty and would have insisted on going to trial.

Facts:

A Pursuant to a plea-bargaining agreement, petitioner William Lloyd Hill 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. Petitioner later filed a federal habeas corpus petition alleging, inter alia, that his guilty plea was involuntary by reason of ineffective assistance of counsel because his court-appointed attorney had misinformed him that if he pleaded guilty he would become eligible for parole after serving one-third of his prison sentence, whereas under Arkansas law petitioner, as a "second offender," was required to serve one-half of his sentence before becoming eligible for parole. The District Court denied habeas relief without a hearing, and the Court of Appeals affirmed.

Issue:

Was petitioner entitled to an evidentiary hearing in a federal habeas proceeding where he has alleged that his guilty plea was entered involuntarily and as a result of ineffective assistance of counsel?

Answer:

No.

Conclusion:

On certiorari, the United States Supreme Court held that the petitioner’s allegations were insufficient to establish grounds for habeas relief. The Court found that the district court properly declined to hold a hearing on the petitioner’s claim of ineffective assistance of counsel because the petitioner had failed to allege the type of prejudice that was necessary to grant relief. The Court stated that the petitioner did not allege in his habeas petition that, had counsel correctly informed him about his parole eligibility date, he would have pleaded not guilty and insisted on going to trial. The Court found that the petitioner alleged no special circumstances that would have supported the conclusion that he placed particular emphasis on his parole eligibility in deciding whether or not to plead guilty.

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