Blackledge v. Allison

Gary Allison (defendant) was charged in North Carolina state court with breaking and entering, attempted safe robbery, and possession of burglary tools. Allison pleaded guilty to a single count of attempted safe robbery, which exposed him to a sentencing range of 10 years to life in prison. At a hearing, the judge asked standard questions from a form; Allison answered the questions and signed the form. In relevant part, the form indicated that Allison understood the possible sentencing range for his plea and that no one had promised Allison anything to induce his plea. The trial court accepted Allison’s plea, and three days later, the court sentenced Allison to 17 to 21 years in prison. No transcripts were available from Allison’s plea colloquy or sentencing hearing. After Allison exhausted his state collateral appeals, he filed a pro se habeas corpus petition in federal district court, alleging that his guilty plea had been induced by an unkept promise of a 10-year sentence. Allison explained that his defense counsel told Allison that his counsel had discussed Allison’s case with the prosecutor and the judge and that Allison would get a 10-year sentence if he pleaded guilty. Allison stated that a third party witnessed Allison’s conversation with his defense counsel. The district court did not hold an evidentiary hearing, instead finding that the trial court had carefully examined Allison before accepting his plea, and Allison’s claim that his defense counsel had incorrectly predicted Allison’s sentence did not warrant relief. The United States Court of Appeals for the Fourth Circuit reversed and remanded the case for an evidentiary hearing, finding that Allison had sufficiently alleged a claim that, if proven, would entitle him to habeas relief and that the government had produced no evidence that conclusively proved that Allison’s claims were false. The United States Supreme Court granted certiorari.