## Facts

- Three New York prisoners pleaded guilty in state court on advice of counsel and were convicted.
- Each later sought collateral relief claiming the guilty plea was induced by a prior coerced confession; one also alleged a judge threatened a maximum sentence if he went to trial.
- State courts denied collateral relief without evidentiary hearings.
- The prisoners filed federal habeas petitions; district courts denied relief without hearings, treating the guilty pleas as waivers of prior nonjurisdictional defects.
- The Second Circuit reversed and ordered evidentiary hearings, reasoning a plea is involuntary if it is the product of an involuntary confession, particularly for pleas entered before Jackson v. Denno invalidated New York’s prior confession-voluntariness procedures.
- The Supreme Court granted review to determine whether an otherwise valid guilty plea can be attacked on collateral review based on allegations that it was motivated by a coerced confession.

## Issues

1. Whether a defendant who pleaded guilty on advice of counsel is, without more, entitled on federal habeas to an evidentiary hearing by alleging the plea was motivated by a prior coerced confession.
2. Whether guilty pleas entered before Jackson v. Denno are rendered involuntary, or show ineffective assistance, because counsel did not anticipate Jackson’s change in confession-voluntariness procedures.

## Decision

- The Supreme Court vacated the Second Circuit’s judgments and remanded.
- A competently counseled defendant who alleges he pleaded guilty because of a prior coerced confession is not, without more, entitled to a federal habeas evidentiary hearing.
- A guilty plea based on reasonably competent advice is an intelligent plea and is not open to collateral attack as involuntary merely because counsel may have misjudged the confession’s admissibility.
- Counsel’s failure to anticipate Jackson v. Denno did not, by itself, establish constitutionally deficient advice.

## Legal Principles

- A guilty plea is an admission of guilt and ordinarily waives later litigation of antecedent constitutional claims about evidence, including confession admissibility.
- Collateral impeachment of a guilty plea based on a coerced-confession theory generally requires a showing that counsel’s advice fell outside the range of reasonably competent professional assistance or that the plea process itself was otherwise constitutionally defective.
- The Sixth Amendment does not require error-free predictions about evidentiary rulings; ordinary misjudgments about admissibility do not alone make counsel ineffective.
- A defendant who pleads guilty under then-existing law assumes the risk of ordinary error in assessing the law and facts; later doctrinal changes do not automatically invalidate the plea.
- A federal habeas court is not required to hold an evidentiary hearing based solely on conclusory allegations that the plea was motivated by a coerced confession.

## Conclusion

The Court held that a guilty plea entered on reasonably competent legal advice is not collaterally invalid merely because it was influenced by an allegedly coerced confession, and that pre-Jackson pleas do not warrant automatic habeas hearings absent facts showing deficient counsel or another constitutional flaw in the plea.


McMann v. Richardson, 397 U.S. 759 (1970)