Hill v. Lockhart
474 U.S. 52 (1985)
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Rule of Law:
To challenge a guilty plea based on a claim of ineffective assistance of counsel, a defendant must satisfy the two-part test from Strickland v. Washington by showing that counsel's performance was deficient and that there is a reasonable probability that, but for counsel's errors, the defendant would not have pleaded guilty and would have insisted on going to trial.
Facts:
- William Lloyd Hill was charged with first-degree murder and theft of property in Arkansas.
- Hill's court-appointed attorney negotiated a plea agreement with the state.
- Pursuant to the agreement, the state would recommend a 35-year sentence for murder and a 10-year concurrent sentence for theft in exchange for Hill's guilty plea.
- Hill's attorney advised him that he would become eligible for parole after serving one-third of his sentence.
- Hill signed a plea statement and pleaded guilty in court.
- Due to a prior felony conviction, Arkansas law classified Hill as a 'second offender,' requiring him to serve one-half of his sentence before becoming eligible for parole.
Procedural Posture:
- William Lloyd Hill pleaded guilty to first-degree murder and theft in an Arkansas state trial court.
- More than two years later, Hill filed a petition for a writ of habeas corpus in the U.S. District Court for the Eastern District of Arkansas.
- The District Court denied habeas relief without an evidentiary hearing.
- Hill appealed to the U.S. Court of Appeals for the Eighth Circuit.
- A divided three-judge panel of the Eighth Circuit affirmed the District Court's judgment.
- The Eighth Circuit, rehearing the case en banc, affirmed the District Court's judgment by an equally divided court.
- The U.S. Supreme Court granted Hill's petition for a writ of certiorari.
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Issue:
Does a defendant's claim of ineffective assistance of counsel, based on an attorney's erroneous advice about parole eligibility, satisfy the prejudice requirement of the Strickland test when the defendant fails to allege that they would have insisted on going to trial but for the error?
Opinions:
Majority - Justice Rehnquist
No. The two-part standard from Strickland v. Washington for evaluating ineffective assistance of counsel claims applies to challenges to guilty pleas. To establish the 'prejudice' prong in this context, the defendant must show a reasonable probability that, but for counsel's errors, he would not have pleaded guilty and would have insisted on going to trial. Petitioner Hill failed to allege in his habeas petition that he would have pleaded not guilty and insisted on going to trial had his counsel correctly informed him about his parole eligibility date. He alleged no special circumstances suggesting that parole eligibility was the dispositive factor in his decision to plead guilty. Therefore, he failed to allege the kind of 'prejudice' necessary to satisfy the second half of the Strickland test, and the lower court did not err in denying him a hearing.
Concurring - Justice White
No. The judgment is correct, but the analysis should focus on the first prong of the Strickland test. Hill's written plea statement indicated he had '0' prior convictions, and he never alleged that he informed his attorney of his prior felony. Without an allegation that the attorney knew of the prior conviction, there is no factual basis to suggest the attorney's advice was incompetent or fell below an objective standard of reasonableness. Had the attorney known of the prior conviction and still given erroneous advice, Hill would have been entitled to a hearing, as his petition did sufficiently allege that the incorrect advice was a critical factor in his decision to plead guilty, thereby satisfying the prejudice prong.
Analysis:
This case is significant for formally extending the two-part Strickland v. Washington test for ineffective assistance of counsel to the guilty plea context. It clarifies the 'prejudice' standard for such claims, requiring a defendant to show that the attorney's error was the dispositive factor in the decision to forgo a trial. This raises the bar for defendants seeking to vacate guilty pleas, thereby reinforcing the principle of finality in the criminal justice system and making it more difficult to challenge convictions that result from plea bargains.
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