Tuesday, November 5, 2013

Hill v. Lockhart case brief

Hill v. Lockhart case brief summary
474 U.S. 52 (1985)

Petitioner inmate pleaded guilty in state court to first degree murder and theft of property. The inmate sought federal habeas relief on grounds that his attorney had failed to advise him that he was required to serve one-half of his sentence before becoming eligible for parole. The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision denying relief. The inmate's petition for certiorari was granted.

The inmate contended that his guilty plea was involuntary as a result of ineffective assistance of counsel because his court-appointed attorney supplied him with information about parole eligibility that was erroneous.


  • On certiorari, the United States Supreme Court held that the inmate's allegations were insufficient to establish grounds for habeas relief. 
  • The Court found that the district court properly declined to hold a hearing on the inmate's claim of ineffective assistance of counsel because the inmate had failed to allege the type of prejudice that was necessary to grant relief. 
  • The Court stated that the inmate did not allege in his habeas petition that, had counsel correctly informed him about his parole eligibility date, he would have pleaded not guilty and insisted on going to trial. 
  • The Court found that the inmate alleged no special circumstances that would have supported the outcome that he placed particular emphasis on his parole eligibility in deciding whether or not to plead guilty.


The Court affirmed the appellate court's judgment upholding the district court's denial of habeas relief.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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