Machibroda v. United States
368 U.S. 487 (1962)
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Rule of Law:
Under 28 U.S.C. § 2255, a federal prisoner is entitled to an evidentiary hearing on a motion to vacate their sentence when they make specific and detailed factual allegations that their guilty plea was involuntary, unless the motion and the files and records of the case conclusively show that the prisoner is entitled to no relief. Allegations of events occurring outside the courtroom, even if improbable, cannot be dismissed without a hearing if they are not palpably incredible.
Facts:
- John Machibroda was charged with robbing two banks in Ohio.
- Machibroda alleged that on three separate occasions, an Assistant U.S. Attorney promised him a total prison sentence of not more than twenty years if he pleaded guilty to both charges.
- The prosecutor allegedly instructed Machibroda not to inform his own lawyer about their conversations and the agreement.
- Relying on these promises, Machibroda waived indictment and pleaded guilty to both bank robbery charges.
- Before sentencing, Machibroda testified as a defense witness at the trial of his co-defendant, Marvin Breaton, denying that Breaton was involved in the robbery.
- After this testimony, the prosecutor allegedly told Machibroda that the judge was vexed and there might be difficulty regarding the promised twenty-year sentence.
- When Machibroda threatened to tell his lawyer and the court about the agreement, the prosecutor allegedly threatened him with additional charges for other robberies but assured him the U.S. Attorney would move to reduce the sentence later if he remained quiet.
- The court ultimately sentenced Machibroda to a total of forty years in prison, consisting of two consecutive sentences of twenty-five and fifteen years.
Procedural Posture:
- John Machibroda was charged by information in the United States District Court for the Northern District of Ohio.
- Represented by counsel, Machibroda waived indictment and pleaded guilty to both charges.
- The District Court sentenced him to consecutive prison terms totaling forty years.
- Nearly three years later, Machibroda filed a motion under 28 U.S.C. § 2255 in the sentencing court to vacate his sentence, alleging his plea was involuntary.
- The District Court denied the motion without holding an evidentiary hearing.
- Machibroda, the appellant, appealed the denial to the U.S. Court of Appeals for the Sixth Circuit.
- The Court of Appeals affirmed the District Court's decision, and the United States was the appellee.
- The U.S. Supreme Court granted certiorari to review the case.
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Issue:
Does a federal district court err by denying a hearing on a motion to vacate a sentence under 28 U.S.C. § 2255 when the prisoner's motion includes specific, detailed factual allegations that his guilty plea was induced by promises from the prosecutor, even if those allegations are improbable and contradicted by the prosecutor's affidavit?
Opinions:
Majority - Mr. Justice Stewart
Yes. A district court errs by denying a hearing when a prisoner makes specific, detailed, and non-frivolous allegations of an involuntary guilty plea based on events outside the record. A guilty plea induced by promises or threats which deprive it of its voluntary character is void and subject to collateral attack. Under 28 U.S.C. § 2255, a hearing is mandatory unless the motion and case records 'conclusively show' the prisoner is entitled to no relief. Here, Machibroda's allegations were specific as to time and place and concerned purported occurrences outside the courtroom, which the record could not conclusively disprove. While the claims were improbable, they were not 'palpably incredible.' The District Court cannot resolve such a controverted issue of fact, which pits the prisoner's affidavit against the prosecutor's, without affording the prisoner a hearing to present evidence.
Dissenting - Mr. Justice Clark
No. The district court did not err because the files and records of the case conclusively show the petitioner's claims to be false. The trial judge, who was familiar with the case from the beginning, correctly found the allegations to be incredible. It is preposterous to believe that an experienced criminal would wait over two years to formally complain about a broken promise, or that a prosecutor would make a deal for testimony that harms, rather than helps, the government's case. Granting a hearing based on such 'Munchausen' tales invites a flood of spurious applications from prisoners seeking a trip out of prison and renders the summary dismissal provision of § 2255 meaningless.
Analysis:
This decision significantly clarifies the procedural requirements for motions under 28 U.S.C. § 2255, establishing a prisoner's right to an evidentiary hearing on claims that cannot be resolved by the existing court record. By setting a high bar for summary dismissal, the Court affirmed that factual disputes over off-the-record events, like alleged promises from a prosecutor, cannot be decided on affidavits alone. The ruling strengthens the ability of defendants to challenge the voluntariness of guilty pleas through collateral attack, ensuring that specific, non-frivolous claims of coercion are tested through the adversarial process of a hearing, even if the claims appear improbable to the presiding judge.
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