Case Citator › Hill v. Lockhart

Hill v. Lockhart

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
474 U.S. 52
Decided
Confirmed treatments
1
Flagged citations read
217 of 218
Citing cases (total)
10,851
Treatment dates
2005
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Hill v. Lockhart has been reviewed, and its strongest confirmed treatment is limited. Of the 218 flagged citations, 217 were read and the 1 confirmed treatment is listed below; the text of the one remaining citing opinion could not be retrieved.
More on how this was screened

United States v. Clifford A. Davis, M.D. confined Hill's post-sentence prejudice test rather than extending it to the more generous standard for a presentence plea-withdrawal motion. The other readable opinions applied Hill, rejected broader readings without narrowing its holding, reported another authority's history, or used nearby adverse language for unrelated law. One withdrawn panel opinion was excluded in favor of its live replacement. The unread opinion is People v. Ubanwa (filed 2025-10-03); its text could not be retrieved from any source, and no treatment was inferred from the words near its citation.

The treatments below are confirmed; unread citations could still change the overall status.
Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case, except the ones whose text could not be retrieved.

10,851 later cases cite Hill v. Lockhart; 218 of those citations sat close to treatment language and were flagged for reading; 217 of them have been read, and the text of 1 citing opinion could not be retrieved, so it remains unread. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Hill v. Lockhart?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • Hill's guilty-plea prejudice requirement governs post-sentence challenges seeking to invalidate a plea, not presentence motions to withdraw a plea under Rule 11(d)(2)(B).

    United States v. Clifford A. Davis, M.D. · Ninth Circuit · filed

    The district court applied the same incorrect legal standard here: requiring defendant to prove that his plea is invalid. The court held that defense counsel’s constitutionally deficient performance could constitute a fair and just reason for withdrawing the plea only if defendant satisfied the prejudice prong of Hill; that is, only if he proved that, but for his counsel’s erroneous advice, he would have insisted on going to trial. See Hill, 474 U.S. at 59, 106 S.Ct. 366. The Hill standard, however, applies when a defendant seeks to invalidate a plea post-sentence. To require a defendant to satisfy the prejudice prong of Hill in order to withdraw a plea based on counsel’s erroneous advice eviscerates the distinction between a motion to withdraw a plea made pre-sentence and a post-sentence challenge to a plea.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

Describe your facts. Ezel reads Hill v. Lockhart and the cases that treated it, then tells you whether it still holds for your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace