## Facts

- Gary Darrell Allison, a North Carolina defendant, pleaded guilty to attempted safe robbery.
- During the plea proceeding, he answered standard questions indicating he understood the possible sentencing range and that no promises or threats induced the plea.
- The trial judge accepted the plea based largely on a written “Adjudication” form stating the plea was free, voluntary, and not induced by promises of leniency.
- Three days later, Allison was sentenced to 17–21 years’ imprisonment.
- After pursuing state collateral remedies, Allison filed a federal habeas petition alleging his lawyer promised—based on discussions with the judge and prosecutor—that he would receive only a 10-year sentence.
- Allison further alleged his lawyer instructed him to deny any promises to ensure the plea would be accepted.

## Issues

1. Whether a state prisoner’s federal habeas petition claiming a guilty plea was induced by an unfulfilled sentencing promise may be summarily dismissed solely because the plea record contains contrary statements disclaiming promises.
2. What threshold showing is required to avoid summary dismissal and obtain further factual development of such a claim.

## Decision

- The Supreme Court affirmed the Fourth Circuit and held the petition should not have been summarily dismissed.
- The Court ruled that the plea record creates a strong evidentiary barrier, but it does not impose a per se bar against collateral challenges.
- Because Allison alleged specific facts explaining both the alleged promise and why he denied it during the plea proceeding, the claim could not be rejected as inherently incredible on the existing record.
- The case was to proceed in the district court for careful consideration and factual development; the Court noted that a full evidentiary hearing might or might not ultimately be necessary.

## Legal Principles

- Representations made during a guilty-plea proceeding, and judicial findings accepting the plea, create a “formidable barrier” to later collateral attacks, and sworn in-court declarations carry a strong presumption of truth.
- Federal courts may not apply a categorical rule that plea-hearing statements foreclose any later claim that the plea resulted from misunderstanding, duress, or misrepresentation.
- Summary dismissal of a habeas petition is proper only when allegations are “palpably incredible” or “patently frivolous or false,” not merely because they contradict the plea record.
- A petitioner must allege specific, nonconclusory facts; sufficiently detailed allegations may require “plenary processing” and a meaningful opportunity to present relevant facts.

## Conclusion

The Court held that a detailed habeas claim alleging an unkept sentencing promise and an explanation for contrary plea-form answers cannot be dismissed solely on the plea record; instead, the claim requires further factual consideration in the habeas proceeding.


Blackledge v. Allison, 431 U.S. 63 (1977)