Hill v. Lockhart

88 L. Ed. 2d 203 · Supreme Court of the United States · 1985

Facts

William Lloyd Hill pleaded guilty to first-degree murder and theft in an Arkansas trial court. He later sought federal habeas relief, alleging his court-appointed attorney misinformed him about his parole eligibility, stating he would serve one-third instead of the actual one-half of his sentence as a second offender. The District Court and Eighth Circuit denied relief without a hearing.

Issue

Does a defendant challenging a guilty plea based on counsel's erroneous advice about parole eligibility need to satisfy the prejudice prong of the Strickland v. Washington test, and if so, what does that entail?

Holding

The Supreme Court affirmed the denial of habeas relief, holding that Hill failed to allege sufficient prejudice under Strickland v. Washington because he did not claim he would have pleaded not guilty and insisted on going to trial had he been correctly advised.

Rule

The two-part Strickland v. Washington test for ineffective assistance of counsel applies to challenges to guilty pleas. To satisfy the prejudice requirement in this context, the defendant must show a reasonable probability that, but for counsel's errors, they would not have pleaded guilty and would have insisted on going to trial.

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Case brief last reviewed 2026-01-08. Prepared by CaseReader from the published opinion.