Sunday, November 3, 2013

McMann v. Richardson case brief

McMann v. Richardson case brief summary
397 U.S. 759 (1970)

Petitioner federal government, by certiorari, sought reversal of three separate judgments of the United States Court of Appeals for the Second Circuit, which directed that a hearing be held on habeas corpus petitions filed by respondent prisoners that were previously denied by the district court.

The three prisoners pleaded guilty to various crimes and asserted in habeas petitions that their pleas were motivated by prior coerced confessions. The circuit court found that a plea was not voluntary if it was based upon an involuntary confession. The federal government challenged the prisoners' right to a hearing on their habeas petitions.

  • The Court held that a prisoner's plea based upon competent advice of counsel was an intelligent plea not open to collateral attack on the basis that counsel may have misjudged the admissibility of the confession. 
  • Therefore, whether a plea was intelligent was dependent upon whether counsel's advice was within the range of competence demanded of attorneys in criminal cases. 
  • On a plea of guilty, a prisoner was convicted on his own counseled admission in open court, and the prior confession was not a basis for judgment. 
  • Thus, the prisoners assumed the risk of ordinary error in his assessment of the law and the facts. 
  • The prisoners were bound by their pleas and convictions unless they alleged and proved incompetence of counsel sufficient to establish that the pleas were not knowingly and intelligently made.


The court vacated the judgments and remanded for reassessment of the prisoners' petitions for habeas corpus.

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

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