United States v. Timmreck
441 U.S. 780 (1979)
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Rule of Law:
A conviction based on a guilty plea is not subject to collateral attack under 28 U.S.C. § 2255 for a mere technical violation of Federal Rule of Criminal Procedure 11 where the defendant cannot show actual prejudice or that the error constituted a fundamental defect resulting in a complete miscarriage of justice.
Facts:
- Respondent was charged with conspiracy to distribute various controlled substances.
- Acting on the advice of counsel, respondent entered into a plea bargain with the prosecutor to plead guilty in exchange for the dismissal of other charges.
- During the plea colloquy, the district judge informed respondent that he could receive a maximum sentence of 15 years' imprisonment and a $25,000 fine.
- The judge failed to inform respondent of a mandatory special parole term of at least three years, which was required by the applicable statute.
- The judge found the plea was voluntary, had a factual basis, and accepted it.
- Respondent was later sentenced to 10 years' imprisonment plus a special parole term of 5 years.
Procedural Posture:
- Respondent did not file a direct appeal from his conviction.
- Approximately two years after sentencing, respondent filed a motion to vacate the sentence under 28 U.S.C. § 2255 in the U.S. District Court, alleging a violation of Rule 11.
- The District Court denied the motion, acknowledging the Rule 11 violation but finding the respondent had not suffered any prejudice.
- Respondent, as appellant, appealed the denial to the U.S. Court of Appeals.
- The Court of Appeals reversed, holding that a Rule 11 violation supports collateral attack even without a showing of prejudice.
- The United States, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does a trial court's failure to inform a defendant of a mandatory special parole term, a technical violation of Federal Rule of Criminal Procedure 11, justify vacating a guilty plea in a subsequent collateral attack under 28 U.S.C. § 2255?
Opinions:
Majority - Justice Stevens
No. A formal violation of Federal Rule of Criminal Procedure 11 does not justify collateral relief when there is no showing of prejudice or constitutional error. Citing the reasoning from Hill v. United States, the Court held that such a violation is neither constitutional nor jurisdictional. To be cognizable in a collateral proceeding, an error must be a 'fundamental defect which inherently results in a complete miscarriage of justice' or an 'omission inconsistent with the rudimentary demands of fair procedure.' Respondent did not argue that he was unaware of the special parole term or that he would have pleaded not guilty if properly advised; his claim was merely a technical violation of the rule. The Court emphasized that the strong interest in the finality of convictions is especially important for guilty pleas, and allowing collateral attacks for technical errors would undermine confidence in judicial procedures.
Analysis:
This decision significantly restricts the ability of defendants to challenge their convictions collaterally based on procedural errors made during a guilty plea. It solidifies the distinction between errors that are reversible on direct appeal and the much narrower category of fundamental defects that warrant relief in a § 2255 proceeding. By requiring a showing of prejudice or a 'miscarriage of justice,' the Court prioritizes the finality of criminal judgments over strict adherence to procedural rules in the context of post-conviction relief. This precedent forces defendants to raise non-constitutional procedural errors on direct appeal, rather than waiting to use them as a basis for a later collateral attack.
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