McMann v. Richardson
397 U.S. 759 (1970)
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Rule of Law:
A defendant who pleads guilty based on the advice of competent counsel cannot later collaterally attack the conviction in a federal habeas corpus proceeding solely on the ground that the plea was motivated by a prior coerced confession. The plea is considered an intelligent choice and a break in the chain of events unless the defendant can prove that counsel's advice was not within the range of competence demanded of attorneys in criminal cases.
Facts:
- Respondent Dash was charged with robbery in 1959. He alleged that he was beaten, refused counsel, and threatened by police into confessing, and that a judge threatened him with a maximum sentence if he went to trial.
- Respondent Richardson was indicted for murder in 1963. He alleged that he was beaten into confessing and that his attorney, after only a 10-minute consultation, advised him to plead guilty to avoid the electric chair, suggesting the confession issue could be raised later.
- Respondent Williams was indicted for multiple felonies in 1956. He alleged he was physically abused and threatened with a pistol during interrogation until he confessed, and that his attorney ignored his alibi defense and misled him about the severity of the charge.
- All three respondents, represented by counsel, entered guilty pleas in New York state courts.
- The guilty pleas for all three respondents were entered prior to the Supreme Court's 1964 decision in Jackson v. Denno, which found New York's procedure for determining the voluntariness of confessions unconstitutional.
Procedural Posture:
- Respondents Dash, Richardson, and Williams each pleaded guilty to felony charges in New York state courts.
- Each respondent unsuccessfully sought collateral relief in the New York state court system.
- Each respondent then filed a petition for a writ of habeas corpus in a U.S. District Court, which denied their petitions without a hearing.
- Respondents appealed to the U.S. Court of Appeals for the Second Circuit.
- The Court of Appeals, acting as the intermediate federal appellate court, reversed the District Courts' decisions in all three cases and ordered that evidentiary hearings be held on their claims.
- McMann, the prison superintendent, petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does a defendant's allegation that he pleaded guilty with the advice of counsel because of a prior coerced confession, without more, entitle him to a federal habeas corpus hearing to challenge the conviction?
Opinions:
Majority - Mr. Justice White
No. A defendant who alleges that he pleaded guilty because of a prior coerced confession is not, without more, entitled to a hearing on his petition for habeas corpus. A counseled guilty plea rests on the defendant's admission in open court, not the prior confession, and waives non-jurisdictional defects like the admissibility of evidence. The defendant's decision to plead guilty is a strategic choice based on his counsel's assessment of the State's case, including the probability of the confession being admitted. To challenge the plea, the defendant must show that his counsel's advice was not 'within the range of competence demanded of attorneys in criminal cases.' The fact that New York's procedure for challenging confessions was later found unconstitutional in Jackson v. Denno does not change this result, as counsel in the pre-Jackson era cannot be deemed incompetent for failing to anticipate a future change in the law.
Dissenting - Mr. Justice Brennan
Yes. A defendant is entitled to a hearing if he can show a sufficient nexus between a coerced confession and a subsequent guilty plea. The presence of counsel does not automatically insulate a plea from the 'abiding impact' of prior unconstitutional state action. Under the 'fruit of the poisonous tree' doctrine, a plea induced by a coerced confession is tainted by the State's illegal conduct. This is especially true for these respondents, who pleaded guilty when New York lacked a constitutionally adequate procedure for challenging confessions, as established in Jackson v. Denno. Denying a hearing is the 'rankest unfairness' and creates an unacceptable rule of 'partial retroactivity' for the Jackson decision.
Analysis:
This case significantly raises the bar for defendants seeking to challenge guilty pleas in federal court. It shifts the legal inquiry from the voluntariness of a pre-plea confession to the voluntariness and intelligence of the plea itself, with a primary focus on the competency of counsel's advice. By treating a counseled plea as a 'break in the chain of events,' the Court prioritized the finality of convictions based on guilty pleas, thereby limiting federal habeas corpus review for a large number of state prisoners. This decision effectively holds that a defendant, through counsel, assumes the risk that a strategic decision to plead guilty may have been based on an incorrect assessment of the law or facts at the time.
