Facts
- William Lloyd Hill, an Arkansas prisoner, pleaded guilty under a plea agreement to first-degree murder and theft of property.
- The state court sentenced Hill, consistent with the prosecution’s recommendation, to concurrent terms of 35 years (murder) and 10 years (theft).
- Hill later sought federal habeas relief, alleging his guilty plea was involuntary due to ineffective assistance of counsel.
- Hill claimed appointed counsel erroneously advised that he would be eligible for parole after serving one-third of his sentence, but Arkansas law required him, as a second offender, to serve one-half before parole eligibility.
- The federal district court denied the habeas petition without an evidentiary hearing, and the Eighth Circuit affirmed.
Issues
- Whether the two-part test for ineffective assistance of counsel from Strickland v. Washington applies to constitutional challenges to guilty pleas based on counsel’s advice.
- In the guilty-plea context, what showing satisfies Strickland’s prejudice prong, and whether Hill’s allegations required an evidentiary hearing.
Decision
- The Supreme Court affirmed the Eighth Circuit’s judgment.
- The Court held that Strickland’s deficient-performance and prejudice framework applies to claims that a guilty plea was induced by ineffective assistance of counsel.
- The Court held that, for guilty pleas, prejudice requires a reasonable probability that, but for counsel’s errors, the defendant would not have pleaded guilty and would have insisted on going to trial.
- Assuming without deciding that incorrect advice about parole eligibility could constitute deficient performance, Hill’s petition failed on prejudice because it did not allege he would have rejected the plea and gone to trial if properly advised.
- Because the pleadings did not satisfy the prejudice requirement, the district court did not err in denying relief without an evidentiary hearing.
Legal Principles
- Ineffective-assistance claims attacking a guilty plea are evaluated under Strickland’s two-prong test: objectively unreasonable performance and resulting prejudice.
- In the plea setting, Strickland prejudice requires showing a reasonable probability that, but for counsel’s errors, the defendant would have pleaded not guilty and insisted on trial.
- A habeas petitioner is not entitled to relief, or to an evidentiary hearing, when the allegations fail to plead facts supporting the required showing of prejudice.
- The Court may resolve an ineffective-assistance claim on prejudice grounds without deciding whether counsel’s performance was constitutionally deficient.
Conclusion
Hill v. Lockhart applied Strickland to guilty-plea challenges and required a plea defendant claiming ineffective assistance to allege and prove that counsel’s error likely changed the decision to plead guilty—specifically, that the defendant would have rejected the plea and demanded a trial.