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A defendant's plea of guilty based on reasonably competent advice is an intelligent plea not open to attack on the ground that counsel may have misjudged the admissibility of the defendant's confession. Whether a plea of guilty is unintelligent and therefore vulnerable when motivated by a confession erroneously thought admissible in evidence depends, as an initial matter, not on whether a court would retrospectively consider counsel's advice to be right or wrong, but on whether that advice was within the range of competence demanded of attorneys in criminal cases. On the one hand, uncertainty is inherent in predicting court decisions; but on the other hand, defendants facing felony charges are entitled to the effective assistance of competent counsel.
Respondents had pleaded guilty in unrelated cases in various New York state courts, and on the basis of their guilty pleas, had been convicted and sentenced, prior to the date of the United States Supreme Court decision in Jackson v. Denno (1964) 378 US 368, 12 L Ed 2d 908, 84 S Ct 1774, 1 ALR3d 1205, which held that certain New York procedures for determining the voluntariness of confessions were unconstitutional. After unsuccessfully applying for collateral relief in the state courts, respondents sought habeas corpus relief in Federal District Courts, alleging that their guilty pleas had resulted from coerced confessions. The District Courts, without granting hearings, denied relief, but the Court of Appeals for the Second Circuit reversed and remanded each of the cases, holding that the allegations in each case concerning the manner in which the confession was coerced and the connection between the confession and the guilty plea were sufficient to require the District Court to hold a hearing, since constitutionally acceptable procedures had, prior to Jackson v. Denno, been unavailable to the convicts to test the voluntariness of their confessions.
Should the court grant respondents’ motion for habeas corpus relief because their pleas were allegedly motivated by prior coerced confessions?
The Court held that a prisoner's plea based upon competent advice of counsel was an intelligent plea not open to collateral attack on the basis that counsel may have misjudged the admissibility of the confession. Therefore, whether a plea was intelligent was dependent upon whether counsel's advice was within the range of competence demanded of attorneys in criminal cases. On a plea of guilty, a prisoner was convicted on his own counseled admission in open court, and the prior confession was not a basis for judgment. Thus, the respondents assumed the risk of ordinary error in his assessment of the law and the facts. The respondents were bound by their pleas and convictions unless they alleged and proved incompetence of counsel sufficient to establish that the pleas were not knowingly and intelligently made.