Tollett v. Henderson
Citation: 411 U.S. 258 (1973) Court: United States Supreme Court
Facts
Henderson pleaded guilty to first-degree murder in Tennessee in 1948. Years later, on habeas corpus review, he sought to challenge the composition of the grand jury that indicted him, arguing that Black citizens had been systematically excluded. The lower courts granted relief, but the State sought review.
Issue
May a defendant who has entered a guilty plea collaterally attack pre-plea constitutional violations — such as the unconstitutional composition of the grand jury — in a habeas corpus proceeding?
Holding
No. The Supreme Court reversed, holding that a guilty plea waives the right to challenge antecedent constitutional violations, including claims of an unconstitutionally composed grand jury.
Rule / Doctrine
A guilty plea represents a break in the chain of events preceding it in the criminal process. After a knowing and voluntary guilty plea, a defendant may not raise independent claims relating to the deprivation of constitutional rights that occurred prior to the plea. The only cognizable attack on a conviction following a valid guilty plea is a claim that the plea itself was involuntary, unknowing, or that counsel was constitutionally ineffective in advising the plea.
Significance
Tollett is a key case limiting the scope of collateral review available to defendants who have pleaded guilty. It pairs with Brady v. United States in defining the consequences of a guilty plea, reinforcing that the plea is a final judgment on antecedent constitutional claims and that defendants must litigate such claims before entering a plea or lose them.