Machibroda v. United States
Citation
368 U.S. 487 (1962)
Facts
After pleading guilty and being sentenced, Machibroda alleged that a federal prosecutor had made secret, unauthorized promises of a lenient sentence in exchange for his guilty plea, rendering the plea involuntary.
Issue
Whether a defendant is entitled to an evidentiary hearing on his claim that a guilty plea was induced by the prosecutor’s unauthorized sentencing promises.
Holding
The Court held that Machibroda was entitled to an evidentiary hearing on his allegations, as the facts alleged, if true, would entitle him to relief.
Rule
A guilty plea induced by a prosecutor’s unauthorized promises is involuntary and violates due process; a defendant is entitled to an evidentiary hearing to prove such allegations if they are specific, detailed, and not conclusively refuted by the record.